Marks in an examination cannot cure the lack of an essential qualification under recruitment rules, holds the Supreme Court

8 October 2026

In Santosh B. Naik versus State of Goa and others, 2026 INSC 1089, the Supreme Court allowed an appeal on eligibility for a government post.
The bench comprised Justice Aravind Kumar and Justice Vipul M. Pancholi.
The post was that of Vocational Instructor (Practical) in the trade of Plumber under the Directorate of Skills Development and Entrepreneurship, Government of Goa.
The Recruitment Rules required an academic qualification with the words under 10+2 system of education forming part of it, along with a National Trade Certificate or National Apprenticeship Certificate in the relevant trade and practical industry experience.
The Court held that while exercising judicial review, courts generally cannot add to or alter the essential qualifications prescribed by the Recruitment Rules.
Whether a candidate's qualification is equivalent to the prescribed one is generally for the employer or a competent expert body to decide.
The Rules did not treat a National Institute of Open Schooling Secondary School Certificate as meeting the 10+2 academic requirement, so the third respondent was rightly found ineligible.
The Court set aside the High Court's direction to consider the third respondent on the basis of his marks and restored the appellant's temporary appointment.