Case Citation:
Supreme Court of India
Allahabad University & Ors. vs. Geetanjali Tiwari (Pandey) & Ors.
Civil Appeal Nos. 12411-12414 of 2024 (with Civil Appeal No. 12415 of 2024)
Date of Judgment: December 18, 2024
Judge: Dipankar Datta
Facts of the Case:
The dispute arose from recruitment for the post of Assistant Professor in Sanskrit at Allahabad University and its affiliated colleges. Geetanjali Tiwari (Pandey), having previously worked as a guest lecturer and contractual faculty, claimed that her teaching experience should count toward marks awarded during shortlisting, as prescribed by the University Grants Commission (UGC) Regulations, 2018. Despite her eligibility and educational qualifications, the University denied her teaching experience marks, interpreting the relevant UGC regulation narrowly.
Contentions of the Appellants:
Allahabad University and affiliated colleges argued that teaching experience gained as a guest lecturer or on a contractual basis could only be counted if the gross emoluments matched those of a regularly appointed Assistant Professor. They cited Regulation 10(f)(iii) of the UGC Regulations, asserting that strict compliance ensured fairness and transparency in candidate evaluation.
Contentions of the Respondents:
Geetanjali Tiwari contended that excluding her teaching experience violated Article 14 of the Constitution, which guarantees equality before the law. She argued that linking teaching experience eligibility to salary was arbitrary and unrelated to academic merit. She asserted that her service met the UGC’s requirements and should be considered for awarding marks.
Issues on This Judgment:
- Whether teaching experience as a guest lecturer or contractual faculty qualifies for marks when shortlisting candidates under the UGC Regulations, 2018.
Observations/Findings by the Supreme Court:
The Court ruled that UGC Regulations must be interpreted as written. Courts cannot rewrite, modify, or expand the scope of statutory regulations unless they are declared unconstitutional. The Court emphasized that the relevant regulation (10(f)(iii)) explicitly linked teaching experience eligibility to specific emoluments. It found that the High Court erred by reading down the regulation without declaring it unconstitutional.
Principles Laid Down by the Court:
- Statutory regulations must be applied as enacted, without judicial amendments unless declared unconstitutional.
- Marks for teaching experience must be awarded only if specific conditions in the regulations are met.
- Judicial review cannot extend to altering policy-based eligibility criteria set by expert regulatory bodies.
Final Order:
The Supreme Court overturned the High Court’s judgment, restoring the original interpretation of UGC Regulations. The appeals were allowed, with no orders as to costs.
Importance of This Judgment to Society:
The judgment reinforces the sanctity of statutory regulations and limits judicial interference in policy-making. It supports merit-based recruitment while ensuring consistent and transparent application of eligibility criteria. This decision prevents arbitrary modifications in recruitment processes, benefiting candidates, academic institutions, and the broader educational system.
