Holding

The recruiting authority’s determination that a Diploma in Electrical and Electronics Engineering is equivalent to the prescribed Diploma in Electrical Engineering is valid, and the appointments of the appellants are upheld.

Summary

The Lakshadweep Electricity Department advertised a Junior Engineer (Electrical) post requiring either a degree in Electrical Engineering or a Diploma in Electrical Engineering with two years' experience. The appellants, holding Diplomas in Electrical and Electronics Engineering, were selected, but the respondents, holding Diplomas in Electrical Engineering, challenged the selection before the CAT, which set aside the appointments on the ground that unstated qualifications could not be read into the advertisement. The High Court upheld the CAT's decision, holding that the appellants did not meet the prescribed qualification. On appeal, the Supreme Court examined the recruitment rules, a clarification from the Kerala Technical Education Department that treated the two diplomas as equivalent, and the employer's acceptance of the equivalence. The Court held that the burden was on the respondents to prove a material difference and that the employer’s assessment of equivalence was reasonable, emphasizing judicial restraint in matters of qualification equivalence. Consequently, the Supreme Court allowed the appeal, set aside the High Court and CAT orders, and restored the appellants' appointments.

Issues considered

Whether the Diploma in Electrical and Electronics Engineering held by the appellants is equivalent to the Diploma in Electrical Engineering prescribed in the recruitment notification.
Whether the recruiting authority’s acceptance of the equivalence of the two diplomas satisfies the qualification requirement under the Lakshadweep Electricity Department Recruitment Rules, 2002.
Whether the High Court erred in setting aside the appointments by taking a technical view of the qualification requirement.

Legislation cited

Lakshadweep Electricity Dept. (Group C and D Technical Posts) Recruitment Rules, 2002

Headnote

Issue for Consideration Whether the appellants' qualifications for the post in question meet the standard prescribed in the recruitment notification. Headnotes† Lakshadweep Electricity Department (Group ‘C’ and ‘D’ Technical Posts) Recruitment Rules, 2002 – An Engineer (Electrical) was issued – The required qualification was specified to be a Degree in Electrical Engineering from a recognized university, or a Diploma in Electrical Engineering from a recognized institution with two years of experience – The appellants are all Diploma-

Subjects

QualificationStandard prescribed in notificationRequired qualificationUnstated qualificationsRecruiting agencyEquivalence of qualificationsTechnical viewAppointmentsService Law

Judgment

[2025] 2 S.C.R. 657 : 2025 INSC 251

Sajid Khan
v.
L Rahmathullah & Ors.
(Civil Appeal No. 17308 of 2017)
20 February 2025
[Pamidighantam Sri Narasimha* and Manoj Misra, JJ.]

Issue for Consideration
Whether the appellants' qualifications for the post in question meet
the standard prescribed in the recruitment notification.

Headnotes†
Lakshadweep Electricity Department (Group ‘C’ and ‘D’
Technical Posts) Recruitment Rules, 2002 – An advertisement
for recruitment to the post of Junior Engineer (Electrical) was
issued – The required qualification was specified to be a Degree
in Electrical Engineering from a recognized university, or a
Diploma in Electrical Engineering from a recognized institution
with two years of experience – The appellants are all Diploma-
holders in Electrical and Electronics Engineering, whereas
the respondents hold a Diploma in Electrical Engineering –
Pursuant to the recruitment process, the appellants were
declared selected – Aggrieved, the respondents filed OA before
the CAT – CAT set aside the selection of appellants and held
that unstated qualifications cannot be read as a part of those
which are specified – Writ petitions by the appellants were
dismissed by the High Court – Sustainablity:
Held: The burden to show that the recruiting authority accepted
the qualifications of the appellants illegally or arbitrarily was on the
respondents who had approached the CAT by filing OAs – There is
nothing on record to show that they had adduced any convincing
material evidence to prove that the qualifications prescribed are
very different from the qualifications possessed by the appellants –
On the other hand, the employer has indicated the efforts made
by it in satisfying that the qualifications are equivalent and that
Diploma in Electrical and Electronics Engineering is the same as

* Author
658 [2025] 2 S.C.R.

Supreme Court Reports

the qualification prescribed in the advertisement – The entire case
of the respondents is based on the difference in nomenclatures
of the two diplomas which stops there and has nothing to do with
the core substance of the courses, including teaching, duration,
curriculum or the pedagogy – Considering the fact that the employer
has not objected to the appellants’ diplomas, it was not appropriate
for the High Court to take a technical view of the matter and set
aside the appointments – In this view of the matter the decisions
of the CAT and that of the High Court are not sustainable in law.
[Paras 22, 23, 24]

Case Law Cited
Anand Yadav v. State of U.P. [2020] 13 SCR 925 : (2021) 12 SCC
390; Mukul Kumar Tyagi v. State of U.P. [2019] 16 SCR 1145 :
(2020) 4 SCC 86; Maharashtra Public Service Commission v.
Sandeep Shriram Warade [2019] 7 SCR 94 : (2019) 6 SCC 362;
Union of India v. Uzair Imran [2023] 13 SCR 1135 : 2023 SCC
OnLine SC 1308 – relied on.
Guru Nanak Dev University v. Sanjay Kumar Katwal [2008] 14
SCR 961 : (2009) 1 SCC 610; District Collector & Chairman,
Vizianagaram v. M Tripura Sundari Devi [1990] 2 SCR 559 : (1990)
3 SCC 655; Ashok Kumar Sharma v. Chander Shekhar [1997] 2
SCR 896 : (1997) 4 SCC 18; Mohd Shujat Ali v. Union of India
[1975] 1 SCR 449 : (1975) 3 SCC 76; Dr. B.L. Asawa v. State of
Rajasthan [1982] 3 SCR 444 : (1982) 2 SCC 55; Zahoor Ahmad
Rather v. Sheikh Imtiyaz Ahmad [2018] 14 SCR 1082 : (2019) 2
SCC 404; Punjab University v. Narinder Kumar (1999) 9 SCC 8;
Uma Shankar Sharma v. Union of India [1980] 3 SCR 730 : (1980)
3 SCC 202 – referred to.

List of Acts
Lakshadweep Electricity Dept. (Group C and D Technical Posts)
Recruitment Rules, 2002.

List of Keywords
Qualification; Standard prescribed in notification; Required
qualification; Unstated qualifications; Recruiting agency;
Equivalence of qualifications; Technical view; Appointments;
Service Law.
[2025] 2 S.C.R. 659

Sajid Khan v. L Rahmathullah & Ors.

Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No. 17308 of 2017
From the Judgment and Order dated 20.11.2014 of the High Court
of Kerala at Ernakulam in WP No. 15398 of 2010
With
Civil Appeal Nos. 17310, 17309, 17311 of 2017

Appearances for Parties
Advs. for the Appellant:
S.P. Chaly, Gaurav Agrawal, Shaji P. Chaly, Sr. Advs., Rajeev
Mishra, Sanand Ramakrishnan, Saiby Jose Kidangoor, A. Karthik,
C. K. Sasi, Ms. Meena K Poulose, Manu Krishnan G.
Advs. for the Respondents:
Shaji P. Chaly, Gaurav Agarwal, Sr. Advs., Rajeev Mishra, Sanand
Ramakrishnan, Amarjit Singh Bedi, Ms. Surekha Raman, Shreyash
Kumar, Harshit Singh, Imlikaba Jamir, M/s. K J John And Co,
Manu Krishnan G, Saiby Jose Kidangoor, C. K. Sasi, Ms. Meena
K Poulose.

Judgment / Order of the Supreme Court

Judgment

Pamidighantam Sri Narasimha, J.

1. We are yet again seized with the common question in recruitment
jurisprudence, whether the appellants’ qualifications for the post in
question meet the standard prescribed in the recruitment notification.
This issue is not novel, and this Court has established clear
guidelines for judicial review and restraint in determining equivalency.
Following these principles, having carefully examined the decision
of the employer (U.T. of Lakshadweep) to recognize the appellants’
qualifications as equivalent, we found it to be both justifiable and
reasonable. Having considered the governing recruitment rules,
submissions of the learned counsel and relevant precedents, we
allow the appeal. Consequently, we set aside the High Court’s
decision, which had held that the appellants lacked equivalent
qualifications and resulted in the termination of their appointments.
660 [2025] 2 S.C.R.

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2. Facts: The brief facts leading to this appeal are as follows. The
Union Territory of Lakshadweep, Department of Electricity had issued
an advertisement for recruitment to the post of Junior Engineer
(Electrical), a Group ‘C’ post. The required qualification was specified
to be a Degree in Electrical Engineering from a recognized university,
or a Diploma in Electrical Engineering from a recognized institution
with two years of experience in any of the fields specified under the
relevant recruitment rules.
3. The appellants are all Diploma-holders in Electrical and Electronics
Engineering, whereas the respondents hold a Diploma in Electrical
Engineering. The appellants and the respondents had participated
in the selection process. Pursuant to the recruitment process, the
authority published a select list on 03.09.2008 as per which the
appellants were declared selected.
4. Aggrieved, the respondents, whose names did not figure in the Select
List, filed Original Applications1 before the Central Administrative
Tribunal2, contending that the appellants held a degree other than
the ones specified in the advertisement, and as such, not qualified
to be appointed to the post.
5. CAT accepted the said contention and by the common order dated
27.01.2010 allowed the original applications and set aside the
appellant’s selection. It relied on the text of the advertisement, and
held that unstated qualifications cannot be read as a part of those
which are specified.
6. Hence, the appellants filed writ petitions3 before the High Court
challenging the CAT’s decision. The Division Bench of the High
Court, by the order impugned before us, dismissed the writ petitions
and upheld the decision of the CAT. The High Court was of the view
that (i) the advertisement was clear in its requirement, and that
the appellants did not possess what was required; (ii) the relevant
recruitment rules, namely the Lakshadweep Electricity Dept. (Group
C and D Technical Posts) Recruitment Rules, 2002, did not provide
for any equivalence between Diplomas in Electrical Engineering

1 Original Application Nos. 91 of 2009, 554 of 2008, and 638 of 2008.
2 Hereinafter referred to as ‘CAT’.
3 Writ Petition Nos. 15398 of 2010, 6014 of 2010, 14891 of 2010 and OP (CAT) No.1305 of 2010.
[2025] 2 S.C.R. 661

Sajid Khan v. L Rahmathullah & Ors.

and Diplomas in Electrical and Electronics Engineering; (iii) the
Lakshadweep Administration had not issued any official instruction
granting such equivalence; and (iv) candidates figuring in the ranked
select-list have no indefeasible right to selection.
7. In this view of the matter, the High Court directed that the select list
be recast by only including candidates who possessed the exact
qualification as prescribed by the advertisement, and the eligible
candidates from the fresh list shall replace the appellants. The
appellants in Civil Appeal Nos. 17308/2017, 17310/2017, 17309/2017
and 17311/2017 are candidates whose name figured in the select
list published by the recruiting authority. Respondent nos. 6-10 in
C.A. No. 17308/2017, respondent nos. 6-10 in C.A. No. 17310/2017,
respondent nos. 4-6 in C.A. No. 17309/2017 and respondent no. 4
in 17311/2017 are employees who were not selected in the process.
These respondents were aggrieved by the appellants’ appointment
contending that the degrees held by the appellants were dissimilar
to the required qualifications.
8. This Court issued notice on 09.01.2015 and the judgment of the High
Court was stayed pending disposal of the Special Leave Petition.
Subsequently, leave to appeal was granted on 12.10.2017 and we
have continued this order until these civil appeals are heard. We
have heard Mr. Shaji P. Chaly, Mr. Gaurav Agrawal, learned senior
counsels, Mr. Rajeev Mishra, Mr. Saiby Jose Kidangoor, learned
counsels appearing for the appellants and Mr. Amarjit Singh Bedi,
learned counsel appearing for the respondents.
9. On behalf of the appellants, it was urged that the two degrees are
similar in nature and no formal declaration of their equivalence was
needed. The only difference between the two is that the Diploma
held by the appellants included a diploma in an additional subject,
i.e, electronics engineering. The syllabus for a Diploma in Electrical
and Electronics Engineering is the same as the one for a Diploma in
Electrical Engineering. Hence, it cannot be said that the appellants
lacked the prescribed qualification.
10. It is also submitted that the recruiting authority was of the view
that the appellants possessed the prescribed qualification and the
diplomas of the appellants were treated at par with the prescribed
qualifications after the Department had received a clarification
662 [2025] 2 S.C.R.

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from the Directorate of Technical Education, Thiruvananthapuram,
Government of Kerala. While the employer took an informed decision
after a technical assessment of the concerned qualifications, the
respondents without establishing how the appellants’ diplomas fall foul
of the required qualifications approached the CAT after the process
was complete. They have submitted that the tribunal and the High
Court have committed an error in both fact and law.
11. Mr. Amarjit Singh Bedi, learned counsel appearing on behalf of the
respondents, fervently and persuasively submitted that equivalence
between degrees is to be found in the rules or are to be specified by
the recruiting authority. In the absence of the same, selections must
and should be made strictly in light of the specified qualifications. Mr.
Bedi submitted that the advertisement does not include a diploma in
Electrical and Electronics Engineering, thereby barring the appellants’
qualification.
12. He relied on the decision of this Court in Guru Nanak Dev
University v. Sanjay Kumar Katwal4, wherein it was stated that
the qualifications have to be taken as exactly as specified, and that
any equivalency cannot be implied or assumed. He would submit
that deviating from the advertisement and accepting candidates with
different qualifications amounts to a fraud on the public, as held in
District Collector & Chairman, Vizianagaram v. M. Tripura Sundari
Devi.5 Relying on Ashok Kumar Sharma v. Chander Shekhar,6 it
was submitted that a public authority shall be strictly held to what it
represented. He concluded his submission by arguing that if equivalent
degrees are to be included, many candidates who did not participate
in the process would have applied.
13. Analysis: We have given our anxious consideration to the arguments
advanced. The relevant rules for the concerned post, namely, the
Lakshadweep Electricity Department (Group ‘C’ and ‘D’ Technical
Posts) Recruitment Rules, 2002 prescribe the requirements in its
Schedule, indicating the name of the post, scale of pay, age, and the
qualifications required. As against Column no. 8 of the schedule, the

4 (2009) 1 SCC 610
5 (1990) 3 SCC 655
6 (1997) 4 SCC 18
[2025] 2 S.C.R. 663

Sajid Khan v. L Rahmathullah & Ors.

Rules prescribe the “educational and other qualifications for direct
recruits” as follows:

THE SCHEDULE
[…]

1. Name of the Post Junior Engineer
[…] […] […]
8. Educational and other (1) Degree in Electrical
qualifications required for Engineering of a recognized
direct recruits University
OR
Diploma in Electrical
Engineering of a recognized
institution with 2 years
Experience in any one of
the following field.
(1) Running and maintenance
of DG Sets
(2) Generation, Transmission
& Distribution of Electricity
(3) Internal electrification of
building
[…]
14. […] […]

14. Soon after these rules, which came into force in 2002, the
administration sought a clarification from the Director, Technical
Education, Kerala regarding the equivalence of the Diploma in
Electrical and Electronics Engineering of the Board of Technical
Education, Tamil Nadu with the Diploma in Electrical Engineering
issued by the Board in Kerala. The relevant portion from the letter
dated 11.02.2003 seeking clarification stated as follows:
“[…] The prospectus showing the syllabus and marks
statements for all the semesters for the three year diploma
664 [2025] 2 S.C.R.

Supreme Court Reports

in Electrical and Electronics Engineering issued by the
Department of Technical Education, Govt of Tamil Nadu,
obtained from one of the contestant are forwarded herewith
as desired. It is requested to kindly clarify whether the three
year Diploma in Electrical and Electronics Engineering
conducted by the Department of Technical Education,
Govt of Tamil Nadu can be considered equivalent to the
qualification of three year diploma in Electrical Engineering
conducted by the Department of Technical Education, Govt
of Kerala so as to adjudge the suitability of the candidature
of certain contestants. […] ”
15. The Department of Technical Education, Govt of Kerala issued a
response to the said clarification on 26.02.2003 stating that both
the qualifications are treated to be equivalent in the State of Kerala.
The relevant portion of this clarification is reproduced as follows:
“[…] I am to inform you that the Diploma Certificate
issued by the Board of Technical Education, Tamil
Nadu is recognized by the Government of Kerala in the
respective branches as per G.O. (MS)-526/Public Services
Department dt. 17.7.1965. […]”
16. Hence, in the year 2003 itself, the Lakshadweep administration had
sought a clarification from another state government’s department
of education about the equivalence which is the basis of the
dispute before us. This position continued without any dispute. On
03.08.2006, the administration issued an advertisement for the post
of Junior Engineer (Electrical). The stipulation of qualifications in the
advertisement has to be read in this context, and the relevant portion
of the advertisement is reproduced as follows:
“[…]

F. No. 36/1/2006-Estt/Ele(1) Dated 03.08.2006

NOTICE
Applications are invited for the appointment to the post
of the Junior Engineer (Electrical) in the scale of pay of
Rs. 5000-150-8000 under the Lakshadweep Electricity
Department from the qualified local candidates from
Lakshadweep Island. Qualifications required as per the
[2025] 2 S.C.R. 665

Sajid Khan v. L Rahmathullah & Ors.

existing recruitment Rules for the appointment to the above
said post are given below.

i. No. of post 2 (Two)
[…] […] […]
iii. Educational Degree in Electrical Engineering
Qualification of a recognized University OR
Diploma in Electrical Engineering
of a recognized institution with 2
years experience in any one of
the following field.
(1) Running and maintenance
of Diesel Generating Sets
(2) Generation, Transmission
& Distribution of Electricity
(3) Internal electrification of
building.
[…]”

17. Given that the recruiting authority had sought a clarification on whether
a Diploma in Electrical and Electronics Engineering is equivalent to a
Diploma in Electrical Engineering and accepted a clarification to the
effect, we do not see any reason in denying such an equivalence for
the purposes of the advertisement. Even the respondents in filing the
OA, did not lay any foundation about why such equivalence should be
denied. Pertinently, the administration had taken a categorical stand
before CAT and the High Court that the two degrees are considered
equivalent for the purposes of recruitment to the said post. Both CAT
and the High Court have ignored the fact that the recruiting authority
had attempted to assess similarities between the two qualifications
before issuing the advertisement.
18. In circumstances where the appointing authority has not objected to
the qualifications of the appellants and there is no apparent or glaring
difference in the qualifications, we see no reason for courts to interfere
and set-aside the appointments made after due consideration. It is
the appointing authority which has to take the decision on whether
the candidate possesses what is required by the post in cases of
666 [2025] 2 S.C.R.

Supreme Court Reports

disputed equivalence. This Court has stated the same in categorical
terms in its decision Anand Yadav v. State of U.P.7:
“32. We may also notice another important aspect i.e.
the employer ultimately being the best judge of who
should be appointed. The choice was of Respondent 2
who sought the assistance of an expert committee in
view of the representation of some of the appellants. The
eminence of the expert committee is apparent from its
composition. That committee, after examination, opined
in favour of the stand taken by the appellants, and
Respondent 2 as employer decided to concur with the
same and accepted the committee’s opinion. It is really
not for the appellants or the contesting respondent to
contend how and in what manner a degree should be
obtained, which would make them eligible for appointment
by Respondent 2.”
(emphasis supplied)

19. The recruiting authority has scrutinised the qualifications before
deciding that they satisfy what is enumerated in the advertisement.
It is not the case of the respondents that the authority in the present
case has not applied its mind in scrutinising the appellants’ diplomas.
In Mukul Kumar Tyagi v. State of U.P.,8 this Court had an occasion
to consider the approach to be adopted by the recruiting agency/
employer while considering the issue of equivalence of qualifications
and directed as under:
“59. The equivalence of qualification as claimed by a
candidate is matter of scrutiny by the recruiting agency/
employer. It is the recruiting agency which has to be
satisfied as to whether the claim of equivalence of
qualification by a candidate is sustainable or not. The
purpose and object of qualification is fixed by employer to
suit or fulfil the objective of recruiting the best candidates
for the job. It is the recruiting agency who is under
obligation to scrutinise the qualifications of a candidate as

7 (2021) 12 SCC 390
8 (2020) 4 SCC 86
[2025] 2 S.C.R. 667

Sajid Khan v. L Rahmathullah & Ors.

to whether a candidate is eligible and entitled to participate
in the selection. More so when the advertisement clearly
contemplates that certificate concerning the qualification
shall be scrutinised, it was the duty and obligation of the
recruiting agency to scrutinise the qualification to find out
the eligibility of the candidates. The self-certification or self-
declaration by a candidate that his computer qualification
is equivalent to CCC has neither been envisaged in the
advertisement nor can be said to be fulfilling the eligibility
condition.”
(emphasis supplied)

20. Similarly, in Maharashtra Public Service Commission v. Sandeep
Shriram Warade9 it was held that:
“9. The essential qualifications for appointment to a post
are for the employer to decide. The employer may prescribe
additional or desirable qualifications, including any grant of
preference. It is the employer who is best suited to decide
the requirements a candidate must possess according to
the needs of the employer and the nature of work. The
court cannot lay down the conditions of eligibility, much
less can it delve into the issue with regard to desirable
qualifications being on a par with the essential eligibility by
an interpretive re-writing of the advertisement. Questions
of equivalence will also fall outside the domain of judicial
review. If the language of the advertisement and the
rules are clear, the court cannot sit in judgment over the
same. If there is an ambiguity in the advertisement or it is
contrary to any rules or law the matter has to go back to
the appointing authority after appropriate orders, to proceed
in accordance with law. In no case can the court, in the
garb of judicial review, sit in the chair of the appointing
authority to decide what is best for the employer and
interpret the conditions of the advertisement contrary to
the plain language of the same.”

9 (2019) 6 SCC 362
668 [2025] 2 S.C.R.

Supreme Court Reports

21. Though there a number of decisions on this very principle,10 we will
conclude with a recent decision of this Court in Union of India v.
Uzair Imran,11 emphasizing the restraint a court must exercise while
determining equivalence between qualifications. The relevant portion
is as under:
“14. Normally, it is not the function of the court to determine
equivalence of two qualifications and/or to scrutinise a
particular certificate and say, on the basis of its appreciation
thereof, that the holder thereof satisfies the eligibility
criteria and, thus, is qualified for appointment. It is entirely
the prerogative of the employer, after applications are
received from interested candidates or names of registered
candidates are sponsored by the Employment Exchanges
for public employment, to decide whether any such
candidate intending to participate in the selection process
is eligible in terms of the statutorily prescribed rules for
appointment and also as to whether he ought to be allowed
to enter the zone of consideration, i.e., to participate in the
selection process. It is only when evidence of a sterling
quality is produced before the court which, without much
argument or deep scrutiny, tilts the balance in favour of
one party that the court could decide either way based
on acceptance of such evidence.”
(emphasis supplied)

22. The burden to show that the recruiting authority accepted the
qualifications of the appellants illegally or arbitrarily was on the
respondents who had approached the CAT by filing OAs. There is
nothing on record to show that they had adduced any convincing
material evidence to prove that the qualifications prescribed are very
different from the qualifications possessed by the appellants. On
the other hand, the employer has indicated the efforts made by it in
satisfying that the qualifications are equivalent and that Diploma in
Electrical and Electronics Engineering is the same as the qualification
prescribed in the advertisement. The entire case of the respondents is

10 Mohd Shujat Ali v. Union of India (1975) 3 SCC 76; Dr. B.L. Asawa v. State of Rajasthan (1982) 2
SCC 55; Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad (2019) 2 SCC 404.
11 2023 SCC OnLine SC 1308
[2025] 2 S.C.R. 669

Sajid Khan v. L Rahmathullah & Ors.

based on the difference in nomenclatures of the two diplomas which
stops there and has nothing to do with the core substance of the
courses, including teaching, duration, curriculum or the pedagogy.
The Court has held that conditions of recruitment such as required
qualifications for a post, have to be viewed reasonably.12
23. Even if some ground exists for the High Court to exercise judicial
review, the standard that the High Court would adopt, as indicated
in Uma Shankar Sharma v. Union of India,13 would be to see that,
“the terms and conditions of service are [intended to be] construed
reasonably, and too technical a view can defeat the essential spirit
and intent embodied in them.” In light of the law re-iterated above
and considering the fact that the employer has not objected to the
appellants’ diplomas, it was not appropriate for the High Court to
take a technical view of the matter and set aside the appointments.
24. In this view of the matter the decisions of the CAT and that of the High
Court are not sustainable in law. Accordingly, we allow the present
appeals by the appointed candidates and set aside the impugned
judgment and order dated 20.11.2014 passed by the High Court in
Writ Petition Nos. 15398 of 2010, 6014 of 2010, 14891 of 2010 and
OP (CAT) No.1305 of 2010.

Result of the case: Appeals allowed.

†
Headnotes prepared by: Ankit Gyan

12 Punjab University v. Narinder Kumar (1999) 9 SCC 8
13 (1980) 3 SCC 202