Supreme Court Rules in Favor of Candidates in Jharkhand Food Safety Officer Recruitment Dispute
The Supreme Court of India recently delivered a landmark judgment in the case of Chandra Shekhar Singh & Ors. vs. The State of Jharkhand & Ors., concerning the eligibility of candidates for the post of Food Safety Officer (FSO) under the Jharkhand Public Service Commission (JPSC) recruitment process. The case revolved around the interpretation of educational qualifications prescribed in the recruitment notification and whether candidates holding postgraduate degrees in relevant subjects were eligible.
The appellants, who held Master’s degrees in Microbiology and Food Science and Technology, were initially selected for the interview stage but later disqualified on the grounds that their degrees did not meet the qualification criteria stipulated in the advertisement. Aggrieved, they approached the High Court, which dismissed their petition. The matter was then taken to the Supreme Court.
Background of the Case
In 2015, the Jharkhand Public Service Commission (JPSC) issued Advertisement No. 01/2016 for the recruitment of Food Safety Officers. The eligibility criteria specified:
“A Degree in Food Technology or Dairy Technology or Biotechnology or Oil Technology or Agriculture Science or Veterinary Sciences or Biochemistry or Microbiology or Master’s Degree in Chemistry or Degree in Medicine from a recognized University.”
The appellants, possessing postgraduate degrees in relevant subjects, applied for the posts and cleared the written examination. However, JPSC later disqualified them, stating that their Master’s degrees did not fulfill the requirement of a ‘degree’ as per the notification. The Jharkhand High Court upheld JPSC’s decision.
Arguments by the Petitioners
The appellants contended:
- The term ‘degree’ as mentioned in the notification should not be narrowly interpreted to exclude postgraduate degrees.
- The University Grants Commission (UGC) defines ‘degree’ to include Bachelor’s, Master’s, and Doctorate degrees.
- The Food Safety and Standards Act, 2006 (FSS Act) stipulates that the qualification for FSOs should be prescribed by the Central Government, not the State Government.
- The JPSC had already accepted their applications and allowed them to proceed to the interview stage before disqualifying them arbitrarily.
- The amendment introduced in the Food Safety and Standards (First Amendment) Rules, 2022 clarifies that Bachelor’s, Master’s, or Doctorate degrees in the relevant subjects are eligible.
Arguments by the Respondents
The respondents, including JPSC and the State of Jharkhand, argued:
- The eligibility criteria clearly mention that only a Bachelor’s degree in the specified subjects is acceptable, except for Chemistry, where a Master’s degree is required.
- The petitioners had applied under the given criteria and could not now challenge the interpretation after participating in the recruitment process.
- The Jharkhand High Court had correctly interpreted the notification and upheld the selection process.
Supreme Court’s Analysis and Observations
The Supreme Court bench, comprising Justices Vikram Nath and Sandeep Mehta, critically examined the statutory provisions and previous judicial precedents.
“The prescription of qualifications for the post of Food Safety Officer is within the exclusive domain of the Central Government. The State Government cannot override or alter the qualifications set by the Central Government.”
“The term ‘degree’ under the UGC Act includes Bachelor’s, Master’s, and Doctorate degrees. Excluding postgraduate degrees in the relevant subjects is an unreasonable and arbitrary interpretation.”
Final Judgment
The Supreme Court set aside the High Court’s decision and ruled in favor of the appellants, directing:
- The appellants’ disqualification from the interview stage was illegal and must be reversed.
- If vacancies do not exist under the 2016 recruitment process, supernumerary posts must be created for the appellants.
- The appellants must be allowed to participate in the interview process, and if they qualify, they should be appointed.
- Their seniority would be below the last selected candidate from the original selection list.
- Successful candidates would not be entitled to back wages but would receive all other service benefits on a notional basis.
Implications of the Judgment
- Clarifies Educational Qualifications: The ruling sets a precedent that postgraduate degrees cannot be arbitrarily excluded from eligibility criteria.
- Strengthens Candidates’ Rights: The decision ensures that recruitment agencies cannot alter eligibility criteria midway through the selection process.
- Reinforces Central Government’s Authority: The judgment affirms that only the Central Government can prescribe qualifications for FSOs.
This landmark ruling has significant implications for future recruitment processes, ensuring that candidates with valid higher qualifications are not unjustly disqualified.
Petitioner Name: Chandra Shekhar Singh & Ors..Respondent Name: The State of Jharkhand & Ors..Judgment By: Justice Vikram Nath, Justice Sandeep Mehta.Place Of Incident: Jharkhand.Judgment Date: 20-03-2025.
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