A) ABSTRACT / HEADNOTE

Chandra Shekhar Singh & Ors. v. The State of Jharkhand & Ors., [2025] 4 S.C.R. 129 ; 2025 INSC 372, examines whether the word degree in the Food Safety and Standard Rules, 2011 and the Jharkhand recruitment advertisement for Food Safety Officer (FSO) can be confined to an undergraduate qualification or whether it embraces postgraduate (and doctoral) qualifications. The appellants holders of Master’s degrees in Microbiology and Food Science & Technology were shortlisted after the written exam but later disqualified by the recruiting authority on the ground that the advertisement required a degree at the graduate level only (with an express exception for Master’s degree in Chemistry).

The High Court sustained the disqualification. This Court analysed the statutory matrix notably ss.37, 91 and 94 of the Food Safety and Standards Act, 2006 and s.22(3) of the University Grants Commission Act, 1956 and the text of Rule 2.1.3 of the FSS Rules 2011. Applying the golden rule of interpretation and relying on the definitional clarity in s.22(3) UGC Act that degree means Bachelor’s, Master’s and Doctorate degrees, the Court held that the unqualified term degree in the rule and the advertisement includes postgraduate qualifications unless expressly excluded.

The special mention of Master’s in Chemistry operates as a positive specification for that subject rather than a limitation excluding Master’s degrees in other listed subjects. The Court allowed the appeal, quashed the High Court orders and directed appropriate remedial measures (including creation of supernumerary posts or consideration from interview-stage), while protecting the seniority of earlier selected candidates.

Keywords: Food Safety Officer; degree; Master’s degree; FSS Rules 2011; UGC Act s.22(3); interpretation of statutes; golden rule.

B) CASE DETAILS

i) Judgment Cause Title: Chandra Shekhar Singh and Others v. The State of Jharkhand and Others.
ii) Case Number: Civil Appeal No. 10389 of 2024.
iii) Judgment Date: 20 March 2025.
iv) Court: Supreme Court of India.
v) Quorum: Two Judges (Vikram Nath and Sandeep Mehta, JJ.).
vi) Author: Mehta, J..
vii) Citation: [2025] 4 S.C.R. 129 ; 2025 INSC 372.
viii) Legal Provisions Involved: Food Safety and Standards Act, 2006 — ss.37, 91, 94; Food Safety and Standards Rules, 2011 — Rule 2.1.3; University Grants Commission Act, 1956 — s.22(3).
ix) Judgments overruled by the Case: High Court of Jharkhand orders dated 30 June 2020 and 2 August 2023 set aside.
x) Related Law Subjects: Administrative law; Constitutional law (Centre–State legislative competence, Articles 246 & 254); Statutory interpretation; Service law / Recruitment law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The dispute arises from a recruitment advertisement issued by the Jharkhand Public Service Commission (JPSC) pursuant to requisition by the State, for appointment as Food Safety Officers under the Food Safety and Standards Act, 2006 (FSS Act). The advertisement required “a degree in Food Technology, Dairy Technology, Biotechnology, Oil Technology, Agricultural Science, Veterinary Sciences, Biochemistry, Microbiology or Master’s degree in Chemistry or degree in Medicine.” Applicants possessing Master’s degrees in relevant subjects applied, cleared the written test and were called for interviews; subsequently they were declared ineligible by the recruiting authority on the ground that the specification contemplated only undergraduate degrees except for Chemistry where Master’s was explicitly permitted.

The appellants challenged their disqualification before the High Court which dismissed their writ petitions; the Division Bench upheld the restriction. The UGC intervened by affidavit conceding generally that degree covers Bachelor’s, Master’s and Doctorate degrees but later qualified that only degrees previously approved by the Central Government would count. The controversy raised both textual and constitutional questions: whether the Rule/ad is to be read in isolation to exclude higher degrees; whether the Central Government’s rule-making power under s.91 yields an exclusive central specification; and whether a narrower recruitment construal by a State authority can stand when the statutory scheme contemplates national uniformity in prescribed qualifications. The Supreme Court accepted the appeal and proceeded to interpret the term degree in the statutory and regulatory matrix.

D) FACTS OF THE CASE

Appellants held post-graduate qualifications in Microbiology and Food Science & Technology and applied to Advertisement No. 01/2016 (JPSC). The advertisement reproduced clause identical to Rule 2.1.3 of the FSS Rules 2011: requiring “a degree in … Microbiology … or Master’s degree in Chemistry …”. Appellants cleared the written stage; when called for interview they were disqualified on the premise that the advertisement intended only graduate (Bachelor’s) degrees for listed subjects, reserving Master’s expressly for Chemistry alone. The appellants filed writ petitions in the High Court; the Single Judge and later the Division Bench held that degree in the listed subjects meant undergraduate qualification and that Master’s in those subjects did not meet the advertisement.

UGC filed counter affidavits with shifting emphasis initially supporting inclusive meaning, later qualifying by reference to Central Government approvals. Appellants invoked earlier precedent Parvaiz Ahmad Parry v. State of Jammu & Kashmir (2015) to contend that possession of higher qualification cannot disqualify a candidate where the requirement mentions degree. The recruiting State resisted, urging the clear text of the advertisement and fairness to other candidates. Supreme Court noted no misrepresentation by appellants, acceptance of their applications, and their call to interview, but their later ejection mid-process. The Court also noted that FSS Act centralised prescription of qualifications (s.37 and s.91) and that State Rules are circumscribed (s.94).

E) LEGAL ISSUES RAISED

i. Whether the word degree in Rule 2.1.3 FSS Rules 2011 and the recruitment advertisement is limited to Bachelor’s degree or includes Master’s and Doctorate degrees?
ii. Whether a State recruitment authority may construe a centrally-prescribed qualification to exclude higher degrees in listed subjects?
iii. Whether disqualifying candidates on account of possession of higher qualifications violates principles of statutory interpretation, equality and reasonableness?

F) PETITIONER / APPELLANT’S ARGUMENTS

i. Counsel submitted the unqualified term degree cannot be restricted to undergraduate level and must include Master’s/Doctorate as per s.22(3) UGC Act.
ii. Reliance on Parvaiz Ahmad Parry that higher qualification cannot be ground for disqualification where requirement mentions degree.
iii. Emphasised centralised rule-making under s.91 and that State action producing arbitrary restriction was impermissible.
iv. Noted later FSS (First Amendment) Rules, 2022 explicitly clarifying Bachelor’s or Master’s or Doctorate — reflecting legislative intent to include higher degrees.

G) RESPONDENT’S ARGUMENTS

i. Respondents argued the advertisement’s explicit phraseology restricted Master’s qualification to Chemistry alone and thus applicants holding Master’s in other listed subjects were not within the eligibility.
ii. Maintained recruitment fairness and adherence to published criteria; applicants cannot expand scope after applying.
iii. Asserted High Court’s concurrent findings were correct and did not warrant interference.

H) RELATED LEGAL PROVISIONS 

i. Food Safety and Standards Act, 2006 — ss.37, 91, 94.
ii. Food Safety and Standards Rules, 2011 — Rule 2.1.3.
iii. University Grants Commission Act, 1956 — s.22(3).
iv. Parvaiz Ahmad Parry v. State of Jammu & Kashmir, (2015) 17 SCC 709.

I) JUDGMENT

The Court held that degree as used in Rule 2.1.3 and the advertisement must be read in the light of s.22(3) UGC Act, which defines degree to encompass Bachelor’s, Master’s and Doctorate degrees. Applying the golden rule and plain meaning, the Court found no textual indication that Master’s degrees in the listed subjects were excluded; the specific reference to Master’s in Chemistry operates as an additional specification not a limiting clause.

The Court emphasised the scheme of the FSS Act: prescription of qualifications is a central function under s.91 and State rules remain subordinate (per s.94). The Court observed the recruiting authority had accepted applications and called appellants for interview procedural acceptance that militated against later disqualification based on a strained reading. Reliance on the legislature’s subsequent amendment in 2022 (explicitly enumerating Bachelor’s, Master’s, Doctorate) reinforced the inclusive interpretation. Applying Parvaiz Ahmad Parry, the Court held higher qualification cannot be a ground for disqualification when requirement stipulates a degree.

Consequently, the High Court orders were quashed; remedies were fashioned to allow appellants to resume at the interview stage or be accommodated by supernumerary posts if vacancies were exhausted, with directions to preserve seniority of earlier selected candidates and denial of back wages while permitting notional service benefits. The appeal was allowed.

a. RATIO DECIDENDI

The decisive principle is that where statutory/regulatory language employs the unqualified term degree, it must be read to include Bachelor’s, Master’s and Doctorate degrees per s.22(3) UGC Act, unless the text expressly restricts the ambit. A special mention (e.g., Master’s in Chemistry) is a positive specification and does not imply negative exclusion of Master’s in other enumerated subjects. Central rule-making power under s.91 confirms uniform national standard for qualifications, and State action cannot impose a contrary narrowing. Procedure and estoppel concerns (acceptance of applications, call to interview) further support relief from arbitrary mid-process disqualification.

b. OBITER DICTA

The Court noted the UGC’s shifting affidavits and observed that degrees accepted must be those recognized/approved by the Central Government where such condition exists; the Court endorsed clarity brought by the 2022 amendment and urged recruiting authorities to adopt plain, unambiguous language in advertisements to avoid litigation. The Court also remarked on preserving rights of previously selected candidates while doing complete justice to aggrieved applicants.

c. GUIDELINES 

i. Recruitment notifications must use unambiguous terminology; if the intention is to restrict to undergraduate degrees, it must be expressly stated.
ii. Where the statutory definition (e.g., s.22(3) UGC Act) defines degree, that definition should inform interpretation of recruitment criteria.
iii. Recruiting authorities should not disqualify candidates mid-process on the basis of narrow semantic construction when applications were accepted and the candidates disclosed qualifications transparently.
iv. Where remedies are required but vacancies are exhausted, creation of supernumerary posts or consideration from the last valid stage is a permissible equitable remedy, subject to protecting incumbents’ seniority.

J) CONCLUSION & COMMENTS

The decision reinforces textual fidelity and purposive harmony: statutory definitions (UGC Act) and central rules (FSS Rules) guide interpretation of recruitment criteria. The Court’s approach protects candidates from arbitrary procedural reversal and underscores the primacy of clear drafting. The relief fashioned balances remedial justice to appellants and protection of incumbents’ seniority, providing a pragmatic template for similar disputes. The judgment also signals that subsequent clarificatory amendments (as in 2022) carry persuasive weight in interpreting earlier ambiguity. Administrative authorities must align advertisement language with statutory definitions and Central rules to preclude avoidable litigation.

K) REFERENCES

a. Important Cases Referred
i. Parvaiz Ahmad Parry v. State of Jammu & Kashmir & Ors., (2015) 17 SCC 709.
ii. Chandra Shekhar Singh & Ors. v. The State of Jharkhand & Ors., [2025] 4 S.C.R. 129 ; 2025 INSC 372.

b. Important Statutes Referred
i. Food Safety and Standards Act, 2006, ss.37, 91, 94.
ii. Food Safety and Standards Rules, 2011, Rule 2.1.3.
iii. University Grants Commission Act, 1956, s.22(3).
iv. Food Safety and Standards (First Amendment) Rules, 2022.