Supreme Court Upholds Rejection of Teachers with Specialized History Degrees: Indresh Kumar Mishra vs. State of Jharkhand (2022)

Introduction

Date of the Judgment: April 13, 2022

Citation: 2022 INSC 386

Judges: M.R. Shah, J. and B.V. Nagarathna, J.

Can a candidate with a postgraduate or graduate degree in a specific branch of history, such as ancient or medieval history, be considered eligible for a teaching position that requires a degree in “History”? The Supreme Court of India recently addressed this question, clarifying the eligibility criteria for postgraduate and graduate teaching positions in Jharkhand. The court examined whether specialized history degrees fulfill the requirement of a general “History” degree as specified in the advertisement for teacher recruitment. The judgment was delivered by a two-judge bench comprising Justice M.R. Shah and Justice B.V. Nagarathna.

Case Background

The case involves multiple appeals concerning the rejection of candidates for the positions of Postgraduate Trained Teachers (PGTT) and Graduate Trained Teachers (GTT) in Jharkhand. These candidates were rejected because they held degrees in specialized branches of history rather than a general degree in “History” as required by the recruitment advertisements.

The Jharkhand Staff Selection Commission (JSSC) initiated a recruitment process for PGTT positions in various subjects, including History, based on requisitions from the Department of School Education and Literacy. Similarly, recruitment for GTT positions in History/Civics was also conducted. The advertisements specified that candidates for PGTT positions in History must hold a postgraduate degree in History, and GTT candidates for History/Civics must have a bachelor’s degree in History and Political Science, with at least 45% marks in one of the subjects.

Many candidates applied, and some were initially declared successful. However, during document verification, it was discovered that many candidates held postgraduate or graduate degrees in specialized branches of history, such as Ancient History, Medieval History, or Ancient History and Culture, rather than a general degree in History. Consequently, show-cause notices were issued, and ultimately, their candidatures were cancelled. This led to the filing of writ petitions in the High Court, which were subsequently dismissed, leading to the present appeals before the Supreme Court.

Timeline

Arguments

Appellants’ Arguments:

• The appellants argued that the advertisements were confusing, particularly for the GTT posts, which mentioned “History/Civics.” They contended that their degrees in specialized branches of history should be considered equivalent to a degree in “History.”
• They submitted that a combined reading of the post requirements and minimum educational qualifications indicated that a graduation in a related subject with a minimum of 45% marks was sufficient.
• The appellants pointed out that they had studied various aspects of history, such as Indian Ancient History, Medieval History, and Modern History, which are all integral parts of the broader subject of “History.”
• They argued that the respondents should not have rejected their candidatures based on the specialization in their degrees, especially since they also studied Political Science (for GTT candidates).
• The appellants further contended that no expert committee was formed to evaluate the qualifications of GTT candidates, unlike the PGTT candidates.
• They emphasized that other states and central government institutions like Kendriya Vidyalaya recognize degrees in specialized branches of history for similar posts.
• The appellants also highlighted the heterogeneity in how different universities confer degrees, with some awarding B.A. in History, while others award B.A. in specialized branches of history.
• They relied on a decision of the Jharkhand High Court in Writ Petition No. 1130 of 2017, which held that the qualification for GTT posts in “History/Civics” was arbitrary and illegal. However, they acknowledged that this decision was stayed by a higher bench.
• The appellants also argued that the universities from where they obtained their degrees do not give a degree certificate in “History” but only in the specific branch of history.

Respondents’ Arguments:

• The respondents argued that the advertisements clearly specified that candidates must have a postgraduate or bachelor’s degree in “History” as a whole, not in a specialized branch.
• They emphasized that for GTT posts, the requirement was a combination of “History/Civics,” necessitating a degree in both History and Political Science.
• The respondents submitted that an expert committee had reviewed the matter and opined that degrees in specialized branches of history do not equate to a degree in “History” as a whole.
• They contended that only candidates with a degree in “History” were selected and appointed.
• The respondents maintained that there was no ambiguity in the advertisement regarding the educational qualifications required.

Submissions

Issues Framed by the Supreme Court

The Supreme Court considered the following issues:

1. Whether the candidates holding postgraduate/bachelor degrees in one of the branches of History, namely, Indian Ancient History, Indian Ancient History and Culture, Medieval/Modern History, Indian Ancient History, Culture and Archaeology, can be said to be possessing the requisite qualification of having a postgraduate/bachelor degree in History as a whole as per the advertisement?

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court considered the following authorities:

Expert Committee Opinion:

• The court noted that an expert committee was formed at the request of JSSC to determine if degrees in specialized branches of history were sufficient. The committee opined that they were not equivalent to a degree in “History” as a whole.

Legal Provisions:

• The court referred to the specific requirements in the advertisement for both PGTT and GTT positions, emphasizing that a degree in “History” was explicitly required.

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• The Expert Committee Opinion was given significant weight by the Court. The Court observed that the Expert Committee opined that the degrees obtained by the candidates in one branch of History cannot be said to be obtaining the degree in History as a whole.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• Clarity of Advertisement: The Court emphasized that the advertisement clearly stated the requirement for a degree in “History” and not a specialized branch of history.
• Expert Opinion: The Court gave significant weight to the expert committee’s opinion that a degree in a specialized branch of history does not equate to a degree in “History” as a whole.
• Need for Comprehensive Knowledge: The Court highlighted that a history teacher must have comprehensive knowledge of all aspects of history, not just one branch.
• Consistency in Application: The Court aimed to maintain consistency in the application of eligibility criteria for both PGTT and GTT positions.

Fact:Law Ratio

The court considered that the advertisement clearly stated the requirements and the expert committee’s opinion was that the degrees obtained by the respective candidates in one branch of History cannot be said to be obtaining the degree in History as a whole. The court reasoned that a history teacher must have comprehensive knowledge of all aspects of history. The court also considered the need for consistency in the application of eligibility criteria for both PGTT and GTT positions.

The Court rejected the argument that the degrees in specialized branches of history should be considered equivalent to a degree in “History”. The Court reasoned that a history teacher must have comprehensive knowledge of all aspects of history, not just one branch. The Court also rejected the argument that there was no expert committee formed for GTT candidates, holding that the same logic applied to both PGTT and GTT candidates.

The Supreme Court upheld the decision of the High Court, stating, “We are in complete agreement with the view taken by the learned Single Judge and the Division Bench of the High Court.” The Court also noted that, “As per the settled proposition of law, in the field of education, the Court of Law cannot act as an expert normally, therefore, whether or not a student/candidate is possessing the requisite qualification should better be left to the educational institutions, more particularly, when the Expert Committee considers the matter.” Further, it was stated that, “There cannot be any deviation from the educational qualifications mentioned in the advertisement.”

Key Takeaways

• Clarity in Advertisements: Educational institutions and recruitment bodies must clearly specify the required qualifications in job advertisements, leaving no room for ambiguity.
• Expert Opinions: Expert opinions play a crucial role in determining the equivalence of educational qualifications in specialized fields.
• Comprehensive Knowledge: For teaching positions, a broad understanding of the subject matter is essential, not just specialization in one area.
• Consistency: Recruitment processes must maintain consistency in the application of eligibility criteria for similar positions.

Directions

The Supreme Court did not issue any specific directions in this case, as it upheld the decisions of the High Court and dismissed the appeals.

Development of Law

The ratio decidendi of the case is that a degree in a specialized branch of history does not meet the requirement of a degree in “History” as a whole for teaching positions. This judgment reinforces the principle that educational qualifications must be strictly adhered to as specified in the recruitment advertisements. The court also emphasized that it is not an expert in the field of education and should defer to the opinion of expert bodies.

Conclusion

In conclusion, the Supreme Court dismissed the appeals, upholding the decision of the Jharkhand High Court. The court ruled that candidates with degrees in specialized branches of history do not meet the eligibility criteria for teaching positions that require a degree in “History” as a whole. The judgment emphasizes the importance of adhering to the specified educational qualifications in recruitment advertisements and the significance of expert opinions in such matters.