6 December 2025 Legal Updates

CANDIDATE CAN'T BE DISQUALIFIED MERELY FOR NOT HAVING DEGREE TITLE IF CORE SUBJECT WAS STUDIED: SUPREME COURT

(a) Case Title: 

• Laxmikant Sharma v. State of Madhya Pradesh & Ors.

(b) Court: 

• Supreme Court of India

(c) Date of Decision: 

• December 4, 2025

(d) Judges: 

• Justice Sanjay Karol & Justice Vipul M. Pancholi

Background

The appellant, Laxmikant Sharma, was appointed as a Monitoring & Evaluation Consultant in 2013 based on an advertisement requiring a “Postgraduate degree in Statistics.” He held an M.com degree with principal subjects in Business Statistics and Indian Economic Statistics. A committee later found him ineligible, leading to termination. The High Court upheld the termination, stating he did not hold a “degree in Statistics.”

Key Issues

• Whether an M.com with Statistics as principal subjects satisfies “Postgraduate degree in Statistics.”
• Whether the termination was arbitrary and violated Article 14 (Equality before Law).

Supreme Court’s Reasoning & Decision

• Interpretation of Qualification: The Court held that insisting only on the degree title without considering the actual curriculum is “form over substance.” Since no Government university in MP offered a degree titled "M.com(Statistics)," a purposive interpretation was necessary.
• Violation of Natural Justice: The initial inquiry committee did not hear the appellant, violating principles of natural justice.
• Expert Opinion Ignored: The Director of the department later certified that the appellant’s subjects met the statistical requirement, but the State ignored this.
• Article 14 & Arbitrariness: The State retained other similarly qualified candidates but terminated the appellant without reasonable classification. This was held arbitrary under Article 14.
• Contractual Employment & Judicial Review: Even in contractual employment, State actions must be fair, non-arbitrary, and reasonable. Courts can review if the decision is irrational or based on irrelevant grounds.

Outcome

Appeal allowed. Termination set aside. Appellant to be reinstated within 4 weeks with consequential benefits.