Punjab and Haryana High Court: In a Letters Patent Appeal, filed against the order which set aside the appointment of the appellant as Lecturer in Political Science, the Division Bench of G.S. Sandhawalia, J. and Jagmohan Bansal, J., held that Master’s Degree in Public Administration is inter-changeable with Master’s Degree in Political Science and it is prerogative of the university to consider degree of Public Administration for the appointment of Lecturer in Political Science.
Background
In the case at hand, Kurukshetra University invited applications for post of Assistant Professor in Political Science. The appellant had Master’s Degree in Public Administration and had also cleared the National Eligibility Test conducted by UGC whereas, the respondent had Master’s Degree in Political Science. The University issued appointment letter to the appellant for the post of Lecturer in Political Science.
The respondent aggrieved from the appointment of the appellant as Lecture in Political Science in spite of the fact that he was not holding Master’s Degree in Political Science filed a civil writ petition before the High Court which passed the order setting aside the appointment of appellant. Hence, the appellant filed a Letters Patent Appeal before this Court against the impugned order.
Analysis, Law and Decision
The Court placed reliance on Rajbir Singh Dalal v. Chaudhari Devi Lal University, Sirsa, (2008) 9 SCC 284 and said that Supreme Court has settled the law that Master’s Degree in Public Administration is inter-changeable with Master’s Degree in Political Science. Besides the order of Supreme Court there are various communications between different authorities like Director General Higher Education, Haryana wherein they have allowed the candidates holding Ph.D./NET in Public Administration be considered for the post of Assistant Professor in Political Science and vice-versa.
The Court also took note of the clarification filed by UGC wherein it has stated that a committee was constituted to consider whether subjects of Political Science and Public Administration can be considered as inter-changeable for the purpose of appointment of Assistant Professor. It was resolved that subjects are inter-dependent yet discerningly distinct in nature. The candidates with Master’s Degree/NET either in Political Science as well as Public Administration may be considered for faculty position in Political Science as well as Public Administration, depending upon the requirement of expertise in the concerned Higher Education Institution which may be decided by the concerned Institution.
Hence, the Court allowed the appeal and held that it was well within domain of appointing authority to appoint appellant as Lecturer in Political Science, though he was holding Master’s Degree in Public Administration.
[Yudhvir v. Reena, LPA 982 of 2017, 2022 SCC OnLine P&H 3430, decided on 10-10-2022]
Advocates who appeared in this case:
Counsel for Appellant:- Senior Advocate R.K.Malik, Advocate Sajjan Singh, Advocate Sunil Hooda;
Counsel for Respondents:- Advocate Palika Monga, Advocate J.S. Dahiya, Advocate Amarjit Singh Virk, Advocate Amit Rao, Advocate Salil Sabhlok.
Excellent interpretation by the author on the caption subject as interchangeable of Public Administration and Political Science for the teachers at secondary and higher education.