Indore News: High Court Dismisses Petition By Assistant Professor Aspirant Over Missing Phd Deadline

Indore (Madhya Pradesh): Indore bench of Madhya Pradesh High Court has dismissed a petition filed by Deepmala Dawar, an aspirant for the assistant professor (chemistry) post, ruling that she did not possess the mandatory PhD qualification by the deadline required under the state’s recruitment advertisement. The order was passed by Justice Jai Kumar Pillai recently.

Dawar had approached the court alleging that her candidature for Madhya Pradesh Assistant Professor Examination, 2022, was rejected due to the authorities’ refusal to accept her documents during the verification stage.

She argued that the delay in obtaining her PhD degree from her university, which was issued on April 23, 2025, was beyond her control and that she had otherwise cleared the written exam held in August 2024.

However, the court held that her claim was “wholly untenable”, noting that the recruitment advertisement explicitly required candidates to possess all educational qualifications, including a PhD where applicable, on or before March 14, 2023, the last date for submission of online applications.

Justice Pillai relied on established Supreme Court rulings to reiterate that the cut-off date for determining eligibility is sacrosanct in public recruitment processes. The judgment cited Ashok Kumar Sonkar vs Union of India and Bedanga Talukdar vs Saifudaullah Khan, both of which stress that eligibility conditions cannot be relaxed unless explicitly provided in the recruitment rules or advertisement.

“Even if the petitioner now possesses a valid PhD degree, her present qualification cannot retrospectively confer eligibility,” the court observed.

Allowing such relaxation, it added, would violate the principles of fairness and equality by disadvantaging candidates who complied with the rules on time.

Dawar argued that her PhD degree was delayed because her university failed to issue it on time, despite multiple reminders and a formal complaint. She claimed that this administrative delay, coupled with her personal difficulties, prevented timely submission.

The court, however, held that such circumstances could not override the mandatory eligibility criteria. Since the petitioner completed her viva only in October 2023 and received her degree in April 2025 - long after the 2023 cut-off - she was never eligible at the stage of application.

The court concluded that Dawar failed to meet the essential qualification within the prescribed timeframe and that the recruitment authority was justified in rejecting her documents. Her plea seeking permission to participate in the interview and document verification process was therefore dismissed.