SC Clarifies – 10th standard through NIOS not equivalent to 10+2 Eligibility for Recruitment
udgment dated 6.10.2026 of the Supreme Court of India in SLP (Civil) No.35916 of 2026 of Santosh B. Naik Vs. State of Goa and others.
The present appeal is directed against the judgment and order dated 11.01.2024 passed by the High Court of Bombay at Goa in Writ Petition No. 272 of 2023, whereby the High Court allowed the writ petition filed by Respondent No. 3 herein, quashed the Minutes of the Meeting dated 23.03.2023 issued by the Departmental Selection Committee as well as the communication dated 12.04.2023, and directed the concerned authorities to consider the case of Respondent No. 3 for recruitment to the post of Vocational Instructor (Practical) in the trade of Plumber, in light of the marks secured by him in the written examination.
Respondent No. 2 i.e., the Directorate of Skills Development and Entrepreneurship, Government of Goa, issued an advertisement dated 05.11.2021 inviting applications for various posts, including the post of Vocational Instructor (Practical) in the trade of Plumber. The Recruitment Rules governing the said post had been notified vide Official Gazette dated 20.04.2006.
The Appellant herein applied for the said post under the unreserved category on 25.11.2021. Respondent No. 3 also applied for the same post. A written examination was conducted on 09.11.2022, in which Respondent No. 3 secured 96 marks, whereas the Appellant secured 94 marks. Thereafter, vide notice dated 08.03.2023, the candidates were called upon to produce documents pertaining to the essential qualifications and other criteria prescribed for the post, for the purpose of verification. The said notice specifically stipulated that selection on the basis of merit was subject to authentication of the requisite documents.
The Departmental Selection Committee found that the respondent no.3 did not possession the essential academic qualification of 10th standard under 10+2 as required by the Recruitment Rules. The appellant was found eligible and was given the post.
However, the High Court found the respondent no.3 as eligible relying on the recognition accorded to the NIOS qualification. It was held that a a candidate who has passed the 10th standard through NIOS is required to be treated as possessing the academic qualification prescribed under the Recruitment Rules.
The question which arises for our consideration is: Whether a candidate possessing the Secondary School Certificate obtained through NIOS satisfies the specific requirement prescribed under the Recruitment Rules and the advertisement of having ‘passed 10th standard under 10+2 system of education’, for appointment to the post of Vocational Instructor (Practical) in the trade of Plumber?
In the present case, the requirement is not merely that the candidate should have passed the 10th standard. The requirement is that the candidate should have “passed 10th standard under 10+2 system of education.” In our considered view, the words “under 10+2 system of education” cannot be ignored. They form part of the qualification prescribed for the post and have to be given their due meaning.
he nature of the post is also relevant. The post in question is that of Vocational Instructor (Practical) in the trade of Plumber. The Recruitment Rules prescribe, apart from the academic qualification, a National Trade Certificate/National Apprenticeship Certificate in the relevant trade and practical experience in the industry. The qualifications prescribed under the Rules are, therefore, part of the eligibility framework for a technical teaching post and have to be considered in that context.
Therefore, we are of the considered view that the Departmental Selection Committee, upon verification of the documents, rightly found Respondent No. 3 not eligible for the post on account of non-fulfilment of the prescribed academic qualification. The said decision was in accordance with the Recruitment Rules and, therefore, did not warrant interference by the High Court.
