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HIGH COURT OF DELHI
JUDGMENT
3449/2026 ARJUN BHARDWAJ & ANR. .....Petitioner
Through: Mr. Sanjeet Paliwal, Adv.
Through: Mr. S. Rajappa, Mr. R.
Gowrishankar and Ms. G.
Dhivyasri, Advs. for R-1.
Ms. Shubhi Bhardwaj, SPC along with Ms. Sahaj Garg, Adv. for R-2/UOI.
Ms. Ananya Sharma, GP.
HON'BLE MR. JUSTICE AMIT MAHAJAN
1. The present petition has been filed assailing the judgment and order dated 07.11.2025 [hereinafter referred to as „impugned judgment‟] passed by the Central Administrative Tribunal, Principal Bench, New Delhi [hereinafter referred to as „Tribunal‟], whereby the Original Application (O.A.) bearing No. 1824/2023, filed by the candidates for the post of TGT (Science) in Kendriya Vidyalaya Sangathan (KVS)/Respondent No.1, including the Petitioners herein, was dismissed.
2. Shorn of unnecessary details, the brief facts leading to the present round of litigation are that the Petitioners, who are graduates with B.Sc. (Hons) in Zoology or Botany, appeared for and qualified the Computer Based Test conducted by the Respondent No.1 for recruitment to various posts pursuant to the Recruitment Notice issued on 02.12.2022. Thereafter, the Petitioners were called for interview, however, at the stage of document verification, their participation was denied on account of lack of requisite qualifications as prescribed under the KVS Revised Recruitment Rules, 2012 [hereinafter referred to as „Rules of 2012‟]. The relevant provision of the KVS Recruitment Rules, 2012 for the post of TGT (Science) reads as under: “Essential Qualification:
(i) Four years‟ Integrated Degree Course of Regional College of
Education of NCERT with at least 50% marks in the concerned subject as well as in the aggregate. OR Bachelor’s Degree with at least 50% marks in the concerned subject/combination of subjects and in aggregate. The concerned subjects are: TGT (Science): Botany, Zoology and Chemistry.
(ii) B.Ed. or equivalent degree from a recognized University.
(iii) Pass in Central Teacher Eligibility Test (CTET), Paper-II, conducted by CBSE in accordance with the Guidelines framed by NCTE for the purpose.
(iv) Proficiency in teaching in Hindi and English medium.”
Aggrieved by such denial, the Petitioners filed an OA before the Tribunal, which was dismissed. The Petitioners have now approached this Court assailing the correctness of the impugned judgment.
3. This Court has heard learned counsel representing the Petitioners at length.
4. It is the case of the Petitioners that they studied Botany as their main subject during their B.Sc. (Hons.) course, with Chemistry being a subsidiary subject only for two semesters in the case of Petitioner No.1 and three semesters in the case of Petitioner No.2, out of total six semesters over a period of three years.
5. Additionally, it has also been argued by the learned counsel for the Petitioner that in order to clarify the ambiguity with respect to the mandatory exposure of subsidiary subject for the Hons. Course, the Respondent No.1 issued a revised TGT (Science) Recruitment Rules, 2025 [hereinafter referred to as „Rules of 2025‟] on 20.03.2025, which prescribed the following qualification for the candidature of TGT (Science). The relevant extract of the Rules of 2025 is provided hereinbelow: “Candidates should have studied Biology/Life Science/Botany/Zoology as Hons/Main Subject in atleast 03 years/ 06 semester of course with following combination of subjects for at least one year or any 2 semesters of the course Main Subject Subsidiary Subjects Biology/Life Science
(i) Chemistry
(ii)Botany/Zoology Botany (i) Chemistry (ii) Zoology Zoology (i) Chemistry (ii) Botany The candidates who studied under Choice Based Credit System (CBCS) with the above subjects are also eligible to apply.” Relying on the aforesaid rules, it is the case of the Petitioners that, they are eligible as per the prescribed qualification provided thereunder.
6. In considered view of this Court, we are not in a position to equate the qualifications of the Petitioners with the prescribed requirement under the Recruitment Rules for the post of Trained Graduate Teacher (TGT) in the Science stream. As per the Rules of 2012, the educational qualifications for TGT (Science) expressly requires the candidates to have studied Botany, Zoology and Chemistry.
7. The Tribunal in Paragraph Nos.[8] and 9 of the impugned judgment, has rightly relied upon the judgments of the Supreme Court to demonstrate the settled position of law that the determination of qualifications and eligibility for appointment lies squarely within the domain of the appointing authority. The Court/Tribunal is not to substitute its own opinion for that of the competent authority unless the action taken is illegal, arbitrary, discriminatory, or violative of constitutional law.
8. In the present case, the Petitioners have not made any arguments with respect to any violation of law or statutory mandate on the part of the Respondents. In the absence of such a claim, this Court cannot enter into an examination of the qualifications themselves, as to whether they are proper or equivalent, or to assess whether the subjects studied by the Petitioners satisfy the prescribed requirements.
9. Therefore, it is clear that, unless the recruitment process has been conducted in contravention of law, or unless the principle of equal treatment is violated, the Courts have no authority to substitute their own view regarding eligibility or qualifications.
10. Moreover, with regard to the second limb of arguments made by the Petitioners that the Rules of 2025, makes them eligible for the requisite post, also holds no merit. The Petitioners cannot rely upon the said rules, to claim eligibility, since the recruitment process, including the Computer Based Test, the interview, and document verification, was governed by the Rules of 2012. Therefore, any subsequent amendment cannot operate retrospectively to confer eligibility on candidate who did not meet the qualifications prescribed under the Rules of 2012.
11. In view of the aforesaid, the present petition, along with pending applications, is dismissed. ANIL KSHETARPAL, J. AMIT MAHAJAN, J. JANUARY 27, 2026 s.godara/hr