Supreme Court Clarifies 'Degree' Definition in Food Safety Officer Recruitment Case

Supreme Court Clarifies 'Degree' Definition in Food Safety Officer Recruitment Case

By: Abhishek Jat, Advocate 

In a significant ruling that impacts recruitment practices and interpretation of educational qualifications, the Supreme Court has delivered a landmark judgment clarifying that the term 'degree' encompasses bachelor's, master's, and doctorate degrees unless specifically excluded. The judgment came in the case of Chandra Shekhar Singh v. State of Jharkhand, wherein the apex court overturned a Jharkhand High Court order that had disqualified candidates holding master's degrees from applying for Food Safety Officer (FSO) positions.

Case Background

The controversy stemmed from a recruitment notification issued by the Jharkhand Public Service Commission (JPSC) on October 7, 2015, for the position of Food Safety Officers. The appellants, who possessed post-graduate qualifications in science with specializations in microbiology, food science, and technology, had applied for these positions. Despite clearing the written examination, they were disqualified during the interview stage on the grounds that their master's degrees did not constitute valid educational qualifications for the FSO position.

The recruiting authorities had interpreted the Food Safety and Standard Rules, 2011 (FSS Rules) to mean that only bachelor's degrees in the specified subjects (except Chemistry, which required a master's degree) would qualify candidates for the position. This interpretation led to the disqualification of several qualified candidates who held higher educational credentials.

Judicial History

The appellants initially challenged their disqualification before the Jharkhand High Court through writ petitions. The Single Judge dismissed their petitions, prompting an intra-court appeal to the Division Bench. During these proceedings, the University Grants Commission (UGC) filed an affidavit confirming that the term 'degree' would include any degree in the specified subjects, whether bachelor's, master's, or doctorate.

Despite this clarification, the Division Bench upheld the disqualification, ruling that the appellants did not possess the required graduation degrees as stipulated in the advertisement. This decision was subsequently challenged before the Supreme Court through special leave petitions.

Supreme Court's Analysis

The Division Bench comprising Justices Vikram Nath and Sandeep Mehta conducted a thorough examination of the relevant laws and regulations. The Court analyzed Sections 37, 91, and 94 of the Food Safety and Standards Act, 2006 (FSS Act), which govern the qualifications and service conditions for FSO positions.

The Court emphasized several crucial points in its judgment:

1. Jurisdiction over Qualification Requirements: The Court highlighted that the prescription of qualifications for FSO positions falls exclusively within the domain of the Central Government, while the power of appointment rests with the Commissioner of Food Safety. State governments are limited to formulating modalities for carrying out the functions assigned to FSOs under the Act.
2. Definition of 'Degree': Citing Section 22(3) of the University Grants Commission Act, 1956, the Court noted that the term 'degree' encompasses bachelor's, master's, and doctorate degrees. Therefore, unless specifically excluded, the term includes all three levels of academic qualifications.
3. Interpretation of FSS Rules: The Court found no ambiguity in the FSS Rules or the recruitment advertisement that would justify excluding master's degrees in subjects other than Chemistry. The Court clarified that the special reference to a master's degree in Chemistry in the Rules meant that this was the minimum qualification for candidates specializing in that subject, while for other subjects, any degree level (bachelor's, master's, or doctorate) would qualify.
4. Constitutional Considerations: The Court observed that excluding candidates with higher qualifications would be unjust, arbitrary, and unconstitutional, as there was no logical rationale for such exclusion.
5. Subsequent Amendments: The Court also took note of the 2022 amendments to the FSS Rules, which explicitly clarified that bachelor's, master's, or doctorate degrees in the specified subjects would constitute valid qualifications for FSO positions.

The Court's Verdict

The Supreme Court set aside the judgments of both the Single Judge and Division Bench of the Jharkhand High Court, ruling unequivocally that the appellants who possessed post-graduate degrees in subjects covered under Clause 2.1.3 of the FSS Rules were fully qualified for the FSO positions under the advertisement.

To ensure complete justice, the Court issued the following directions:

1. If vacancies no longer existed from the 2016 recruitment process, the respondents were directed to create supernumerary posts to accommodate qualified appellants.
2. The appellants were to be allowed to participate in the recruitment process from the interview stage, from which they had been wrongfully disqualified.
3. Appellants who succeeded in the interviews and ranked on par with or higher than the last successful candidate in their category were to be offered appointments effective from the date of publication of the first select list in the 2016 recruitment process.
4. To protect the interests of previously selected candidates who were not parties to the litigation, successful appellants would be placed below the last candidate selected and appointed in the original selection process.
5. While the successful appellants would not be entitled to back wages, they would receive all service benefits on a notional basis.

Implications of the Judgment

This judgment has far-reaching implications for recruitment practices across various government departments, particularly regarding the interpretation of educational qualifications. By clarifying that the term 'degree' encompasses all levels of academic qualifications unless specifically excluded, the Supreme Court has established a precedent that promotes fairness and prevents arbitrary disqualification of candidates with higher educational credentials.

The ruling also underscores the importance of precise language in recruitment notifications and service rules, particularly when specifying educational qualifications. Public service commissions and recruiting authorities will need to explicitly state any exclusions regarding higher degrees if such exclusions are intended.

Furthermore, the judgment highlights the Court's commitment to interpreting recruitment rules in a manner that is consistent with constitutional principles of equality and non-arbitrariness, preventing the unjust exclusion of well-qualified candidates from public employment opportunities.

In essence, this landmark decision ensures that candidates are not penalized for possessing higher educational qualifications than minimally required, thus promoting meritocracy in public service recruitment while safeguarding candidates' legitimate expectations when applying for government positions.

Case Title : Chandra Shekhar Singh v. State of Jharkhand

 Citation: 2025 SCC OnLine SC 595

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified legal professionals for specific legal concerns.