Supreme Court addressing a civil appeal concerning the eligibility criteria for Food Safety Officer (FSO) appointments in the State of Jharkhand. The appellants, holding postgraduate degrees, were disqualified despite clearing written exams, as the respondents argued their Master’s degrees did not meet the specific “degree” requirement outlined in the 2015 notification, which restricted Master’s degrees to Chemistry only. The Court examines the Food Safety and Standards Act, 2006 (FSS Act) and University Grants Commission (UGC) regulations to determine if the term “degree” encompasses Master’s degrees in subjects other than Chemistry, ultimately overturning the High Court’s decision. The ruling clarifies that a Master’s or Doctorate degree in the specified fields (like Microbiology or Food Technology) should indeed qualify candidates for FSO positions, leading to a directive for the appellants to be considered for appointment.
Food Safety and Standards Act, 2006, Sections 37, 91 and 94 – Food Safety and Standard Rules, 2011, Rule 2.1.3 – University Grants Commission Act, 1956, Section 22(3) – Service Law – Eligibility – Recruitment – Food Safety Officers – Qualification – Expression ‘degree’ – Post of appellants laid a claim for the posts in question by disclosing that they were possessed of Master’s degrees in Microbiology; Food Science and technology subjects – Thus, there was no ambiguity or misrepresentation by the appellants regarding their educational qualification at the time of applying in the subject recruitment process – The respondent-recruiting authority consciously accepted the application forms of the appellants and pursuant to their performance on merit, the appellants were called for an interview – It is at this stage that the appellants were declared disqualified and were ousted from the selection process on the premise that they were holding Master’s degrees in the relevant subject/s, whereas the rules and the advertisement clearly provided that the required degree should be at the graduate level only – Held that the term ‘degree’ is defined under Section 22(3) the UGC Act, which states that the ‘degree’ means the ‘Bachelor’s Degree’, ‘Master’s Degree’ and the ‘Doctorate Degree’ – Thus, wherever the word ‘degree’ is used, unless a specific exclusion is provided, the same would include within its scope and ambit all three, ‘Bachelor’s Degree’, ‘Master’s Degree’ and a ‘Doctorate Degree’ – There is no ambiguity whatsoever in the FSS 2011 Rules or the subject advertisement which can exclude the Master’s degree in subjects referred to in the preceding part of the Rule 2.1.3 of the FSS 2011 Rules, other than Chemistry, as being a valid qualification – The special reference to the Master’s degree is given in the said Rule, only for those who have acquired their degree course in Chemistry subject, for whom, the minimum qualifying criterion will be a Master’s degree in Chemistry – However, so far as the other subjects are concerned, a person having any degree, be it graduation or post-graduation, would be equally qualified for the post in question – Appellants, who possessed post-graduate degrees in subjects covered under Clause 2.1.3 of the FSS 2011 Rules, were definitely and unquestionably qualified for the post of FSO under the subject advertisement – Impugned judgments rendered by the Division Bench and the Single Bench, holding that the appellants were not qualified for the post of FSO, are quashed and set aside.
(Para 29 to 35)
Chandra Shekhar Singh V. State Of Jharkhand
Supreme Court: 2025 INSC 372: (DoJ 20-03-2025)
