Summary
The Court upheld the Bank’s cancellation of a peon candidate’s candidature. The advertisement expressly excluded graduates, consistently with the Bank’s recruitment policy, and the candidate deliberately concealed his degree. The employer’s prescription was justified for this post; courts could not replace it by treating a higher qualification as automatically sufficient. Both High Court orders directing that he be allowed to work were set aside.
Issues
- Whether a graduate could claim appointment despite the express recruitment condition excluding graduates.
- Whether deliberate concealment of the degree justified cancellation of candidature.
Held
- The advertisement and applicable Bank circular expressly required a twelfth-standard qualification and excluded graduates. The candidate participated without challenging that condition and could not subsequently claim that his higher qualification could not disqualify him. (¶¶ 5, 5.1, 5.2, 6)
- The employer has latitude to prescribe relevant qualifications according to institutional needs and the nature of the post, while remaining subject to the prohibition on arbitrary or fanciful requirements. The Bank’s conscious decision to exclude graduates for this subordinate post was justified; the courts could not substitute their own assessment. (¶¶ 7, 7.1, 7.2, 7.3)
- A higher qualification does not necessarily establish eligibility contrary to the prescribed recruitment requirements. Decisions permitting higher qualifications under a specific enabling statutory rule do not supply a universal rule applicable in its absence. (¶¶ 7.2, 7.3)
- The candidate deliberately withheld his graduation in the application and bio-data, although disclosure would have excluded him from consideration. That material suppression independently defeated the claim for relief, and the Bank rightly cancelled his candidature before he joined. (¶¶ 5.2, 8, 9)
Result
Appeal allowed. Both High Court orders directing the Bank to allow the respondent to discharge duties as peon were quashed and set aside. No costs imposed.