The matter arose from a petition filed by Bhagat Prashant Haribhau, who sought to continue in the recruitment process for the post of Senior Trainee (Marketing) advertised by the National Seeds Corporation (NSC). Haribhau possessed a Bachelor of Science in Agricultural Business Management and a Master of Business Administration in Agriculture. He contended that his bachelor’s degree was substantially equivalent to the Bachelor of Science in Agriculture prescribed in the advertisement and that NSC’s refusal to consider his candidature on the basis of nomenclature alone was unduly technical.
NSC maintained that the advertisement expressly required a B.Sc. (Agriculture) qualification and did not contain any language permitting the acceptance of equivalent degrees. The corporation argued that determining equivalence lay within its domain and that accepting the petitioner’s plea would amount to altering the eligibility criteria after the selection process had commenced.
Justice Sanjeev Narula, delivering the judgment, observed that a recruitment notice functions as the charter of the selection process, informing prospective applicants across the country of the precise qualifications that render them eligible to apply. The Court emphasized that, once the selection process has begun, expanding the criteria by recognising qualifications not mentioned in the notice would prejudice those candidates who, having read the advertisement as it stood, chose not to apply because their qualifications were not recognised.
The Court held that it could not read the words “or equivalent” into the advertisement when the employer had deliberately omitted them. Such an exercise would not constitute interpretation but would amount to rewriting the terms of the notice. The judgment clarified that the determination of equivalence is not a mere comparison of course titles or overlapping subjects; it requires an assessment of academic standards, course content, duration, practical exposure, institutional objectives, and the suitability of the qualification for the specific post.
Further, the Court noted that the recruitment in question was an all‑India process. Permitting different States or universities to apply their own equivalence regimes after the advertisement had been issued would lead to varying eligibility criteria being applied to the same recruitment, thereby undermining the uniformity essential to public employment selections. The Court stated that such flexibility would be permissible only if the employer itself had incorporated equivalence into the advertisement or otherwise recognised it under the governing recruitment framework.
In the absence of any such recognition, the Court directed that the recruitment must proceed strictly in accordance with the qualifications prescribed in the advertisement. Justice Narula underscored that fairness in public recruitment is owed not only to the candidate before the Court but equally to those who refrained from applying because the advertisement did not recognise their qualifications. The discipline of public recruitment, the Court observed, requires the judiciary to hold the employer to the criteria it notified rather than to reconstruct those criteria after the selection process has commenced.
The petition was consequently dismissed, and NSC’s decision to reject Haribhau’s candidature was upheld. The ruling reinforces the principle that recruitment notices bind both applicants and employers, and that judicial intervention cannot expand the notified eligibility criteria once the selection process has been set in motion.