CHANDRA SHEKHAR SINGH AND OTHERS versus THE STATE OF JHARKHAND AND OTHERS

CHANDRA SHEKHAR SINGH AND OTHERS versus THE STATE OF JHARKHAND AND OTHERS

Section 22(3) of the UGC Act defines 'degree' to include Bachelor's, Master's and Doctorate degrees; Clause 2.1.3 of the FSS Rules and the recruitment advertisement did not expressly exclude Master's degrees for the listed subjects (except that Chemistry specifically required a Master's); therefore Master's degrees in the specified subjects satisfy the qualification for Food Safety Officer and the appellants were wrongly disqualified; the High Court judgments were set aside.

Parties
Appellants: Chandra Shekhar Singh and Others; Respondents: The State of Jharkhand and Others
Jurisdiction
India
Judgment Date
19 March 2025
Procedural Posture
Civil Appeal / Appeal From High Court Judgment (lpa No. 244 of 2020)
Outcome
Appeal allowed
Legal Topics
Interpretation of 'degree' in Statutory/advisory Context, Qualification for Appointment as Food Safety Officer, Central Government Rule Making Versus State Government Rule Making, UGC Definition of 'degree', Application of Food Safety and Standard Rules, 2011 and Amendment 2022
Food Safety Regulation Administrative Law Constitutional Law Education Law Employment Law Statutory Interpretation Interpretation of 'degree' in Statutory/advisory Context Qualification for Appointment as Food Safety Officer +3 more

Case Brief

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Parties

Chandra Shekhar Singh and Others

Appellants

The State of Jharkhand and Others

Respondents

Procedural Posture

Civil Appeal / Appeal From High Court Judgment (lpa No. 244 of 2020)

Legal Issues

  1. 1 Whether the term 'degree' in the FSS Rules and the recruitment notification includes Master's degrees
  2. 2 Whether appellants holding Master's degrees in specified subjects were lawfully disqualified from appointment as Food Safety Officers

Ratio Decidendi

Section 22(3) of the UGC Act defines 'degree' to include Bachelor's, Master's and Doctorate degrees; Clause 2.1.3 of the FSS Rules and the recruitment advertisement did not expressly exclude Master's degrees for the listed subjects (except that Chemistry specifically required a Master's); therefore Master's degrees in the specified subjects satisfy the qualification for Food Safety Officer and the appellants were wrongly disqualified; the High Court judgments were set aside.

Court Disposition

Appeal allowed

Orders

  • Impugned judgments of the Division Bench dated 02.08.2023 and Single Bench dated 30.06.2020 quashed and set aside.
  • Appellants shall be allowed to partake in the recruitment process from the stage they were disqualified (interview stage); if vacancies do not exist in the 2016 recruitment, respondents shall create supernumerary posts to accommodate appellants.