A recognised qualification is not the same as the qualification the rules ask for. The Supreme Court has held that courts exercising judicial review ordinarily cannot add to or alter the essential qualifications prescribed under recruitment rules.A bench of Justice Aravind Kumar and Justice Vipul M. Pancholi, in Santosh B. Naik v. State of Goa & Ors. (2026 INSC 1089), set aside a Bombay High Court at Goa ruling that had opened the door for a candidate holding a National Institute of Open Schooling (NIOS) Secondary School Certificate to be considered for the post of Vocational Instructor (Practical) in the trade of Plumber. The sticking point was a few words in the Recruitment Rules: "passed 10th standard under 10+2 system of education". The Supreme Court held that the words "under 10+2 system of education" could not be ignored. It also held that scoring higher marks in the written examination could not cure the absence of an essential qualification.The Court restored the Departmental Selection Committee's decision and the appellant's temporary appointment. The Court drew a firm boundary around the ruling. Its conclusion is confined to the Recruitment Rules for this post and the advertisement dated 05.11.2021, and it expressed no opinion on NIOS qualifications for any other purpose or under any other set of recruitment rules.Factual BackgroundOn 05.11.2021, the Directorate of Skills Development and Entrepreneurship, Government of Goa, advertised various posts, including Vocational Instructor (Practical) in the trade of Plumber. The Recruitment Rules for the post had been notified in the Official Gazette dated 20.04.2006. The prescribed qualifications were:Academic: Passed 10th standard under 10+2 system of educationTechnical: National Trade/National Apprenticeship Certificate in the tradeExperience: Practical experience of not less than 5 years in the industryThe appellant applied under the unreserved category on 25.11.2021, as did Respondent No. 3. In the written examination held on 09.11.2022, Respondent No. 3 secured 96 marks and the appellant 94. By notice dated 08.03.2023, candidates were asked to produce documents for verification, and the notice stipulated that selection on merit was subject to authentication of the requisite documents.On 23.03.2023, the Departmental Selection Committee found that Respondent No. 3 did not possess the essential academic qualification of having passed 10th standard under the 10+2 system, and held him ineligible. The appellant was found eligible and placed in the Final Selection List. He was offered the post by Memorandum dated 24.03.2023 and accepted it on 27.03.2023.Proceedings Before the High CourtRespondent No. 3 challenged the decision before the High Court in Writ Petition No. 272 of 2023. He contended that he held the requisite academic qualification through the Secondary School Certificate Examination conducted by NIOS in June 2004, in which he had cleared English, Home Science, Science, Economics and Hindi. It was not in dispute that he had the required technical qualification and experience, so the controversy was confined to the academic qualification.By judgment dated 11.01.2024, the High Court accepted his case, relying on the recognition accorded to the NIOS qualification and the material he had produced. It held that a candidate who has passed the 10th standard through NIOS must be treated as possessing the prescribed academic qualification. It quashed the Committee's minutes of 23.03.2023 and the communication dated 12.04.2023, and directed that Respondent No. 3 be considered for recruitment in light of his marks.Arguments Before the Supreme CourtThe appellant submitted that the High Court overlooked the precise wording of the Rules, which require not merely a pass in the 10th standard but a pass "under 10+2 system of education". He argued that the expression was deliberately incorporated given the nature of the post, which falls in the Engineering Trade category. According to him, the 10+2 system, as envisaged in the National Policy on Education, is a structured course of formal schooling in which Science and Mathematics are compulsory, whereas Respondent No. 3 had not studied Mathematics. He further argued that the High Court had effectively introduced a concept of equivalence into Rules that contain none, and that merit in the written examination arises only among candidates who meet the essential eligibility criteria. He also relied on the 2015 recruitment process for the same post, in which, by minutes dated 16.11.2015, the Committee had found him ineligible because he held an NIOS Secondary School Certificate.The State of Goa and the Directorate (Respondent Nos. 1 and 2) submitted that the process was conducted strictly in accordance with the Rules, and that the expression could not be read to include every qualification recognised as equivalent to the 10th standard in the absence of an equivalence clause. They described the "10+2 system" as a structured formal system of primary, middle and high school education with compulsory subjects, and said NIOS, as an open schooling model, does not mandate such subjects. They added that the Department had consistently applied this interpretation, including in 2015, and that recognition of the NIOS certificate by the Goa Board could not override the specific eligibility requirement.Respondent No. 3 submitted that he held all essential qualifications and the highest marks, and that his original documents, including the NIOS certificate, were produced for verification without objection from the Department at that time. He argued that the NIOS certificate is a valid, recognised qualification, relying on notifications and communications of the Association of Indian Universities and the Ministry of Human Resource Development, particularly the communication dated 05.10.1993, which he said recognised NIOS Secondary Examination as equivalent to the Class 10 examination of recognised Boards, including for employment. He contended that "10+2 system of education" cannot be read as limiting eligibility to conventional schooling, since neither the Rules nor the advertisement expressly exclude recognised open-schooling qualifications. He also pointed out that he had served as a Guest Lecturer for the Plumber Trade course at the Government Industrial Training Institute, Pernem, from 18.03.2021 to 31.08.2022.Supreme Court's ObservationsThe Court noted that the relevant facts were not in dispute and framed the question as whether a candidate holding an NIOS Secondary School Certificate satisfies the specific requirement of having "passed 10th standard under 10+2 system of education".The Court reiterated that qualifications prescribed by the recruiting authority must be satisfied in the manner prescribed, and that whether a candidate's qualification is equivalent to the prescribed one is ordinarily within the domain of the employer or the competent expert body. This principle, it said, was reiterated in Zahoor Ahmad Rather & Ors. v. Sheikh Imtiyaz Ahmad & Ors., Unnikrishnan C.V. & Ors. v. Union of India & Ors. and Shifana P.S. v. State of Kerala & Ors."The Court, while exercising judicial review, ordinarily cannot add to or alter the essential qualifications prescribed under the Recruitment Rules."Citing Reserve Bank of India v. Peerless General Finance & Investment Co. Ltd., the Court said interpretation must depend upon the text as well as the context, and that words used by the rule-making authority cannot be ignored. It held that the words "under 10+2 system of education" form part of the prescribed qualification and must be given their due meaning."The question, therefore, is not whether the Secondary School Certificate issued by NIOS is a recognised qualification in general. The question is whether such qualification satisfies the specific eligibility condition prescribed under the Recruitment Rules for the post in question."The Court observed that the Rules contain no provision treating a qualification recognised as equivalent to the 10th standard as satisfying the requirement of the 10+2 system.On precedent, the Court recorded that Zahoor Ahmad Rather held that qualifications must be considered having regard to the duties and responsibilities of the post, and that a court cannot substitute its view for that of the recruiting authority. Unnikrishnan C.V. and Shifana P.S. reiterated that judicial review cannot be used to expand prescribed eligibility conditions or treat a non-prescribed qualification as equivalent. Maharashtra Public Service Commission v. Sandeep Shriram Warade held that prescribing essential qualifications is within the employer's domain, and that courts cannot substitute their own view where the language of the advertisement and Rules is clear.The Court also noted the nature of the post, a technical teaching post for which the Rules prescribe, besides the academic qualification, a trade certificate and industry experience.On the 2015 process, the Court observed that the appellant himself had participated and had been found ineligible on the same ground. This was relevant only "for the limited purpose" of showing the employer's consistent interpretation, and the Court clarified it was not treating the earlier decision as binding precedent.The Court held that recognition of the NIOS qualification by the Goa Board or other authorities may establish its acceptability for the purposes for which it is granted, but cannot by itself amend or enlarge the eligibility condition under the Rules. It also rejected the relevance of higher marks, holding that comparative merit arises only among candidates who satisfy the eligibility conditions."The marks secured in the written examination cannot cure the absence of an essential qualification prescribed under the Recruitment Rules."Click Here to Read the Official JudgmentSupreme Court's DecisionThe Court held that the Departmental Selection Committee had rightly found Respondent No. 3 ineligible, in accordance with the Recruitment Rules, and that the High Court's interference was unwarranted. It found that the High Court had committed a grave error. Allowing the appeal, it directed:The High Court's judgment dated 11.01.2024 is set aside.The appointment of Respondent No. 3 under Memorandum dated 19.02.2024 and final appointment order dated 11.06.2024 also stands set aside.The Departmental Selection Committee's decision dated 23.03.2023 is restored.The appellant's temporary appointment under that selection and the Memorandum dated 24.03.2023 is restored, subject to the applicable terms and conditions of service.The Court expressly confined its conclusion to the Recruitment Rules applicable to the post and the advertisement dated 05.11.2021. It clarified that it expressed no opinion on the validity, recognition or equivalence of NIOS qualifications for any other purpose or under any other set of Recruitment Rules.Important Link Law Library: Notes and Study Material for LLB, LLM, Judiciary, and Entrance Exams