Summary
The Court held that Kurukshetra University’s correspondence diploma in Art and Craft did not satisfy the advertised equivalent-qualification requirement for Haryana Arts and Crafts teachers. Recognition of a course differs from recognition of its equivalence to the prescribed teacher-training qualification. The High Court could not substitute its assessment for the competent authorities’ supported technical evaluation of course content and practical training.
Issues
- Whether the correspondence diploma was an equivalent qualification for the advertised teacher posts.
- Whether the High Court could equate the two courses contrary to the competent authorities’ assessment.
Held
- The advertisement required the Haryana Industrial Training Department’s two-year diploma or an equivalent qualification recognized by the Haryana Education Department. The correspondence diploma lacked the required equivalence; the University’s own notices did not promise teacher appointment. (¶¶ 4, 13, 14, 15, 18, 19, 20)
- The regular course’s practical teaching, internal assessment and admission arrangements materially differed from the correspondence course. General recognition of a University course did not establish equivalence to this prescribed vocational qualification. (¶¶ 14, 17, 20)
- Equivalence is a technical academic matter for the competent authority, not an assumption for a court to make. Supported expert decisions are not lightly disturbed, while review remains available for extraneous considerations, mala fides, irrationality, perversity or manifest error. (¶¶ 21, 22, 23, 24, 25, 26)
Result
Appeal allowed. The High Court judgment in CWP No. 20630 of 2006 and connected matters was set aside and the writ petitions dismissed; no costs.