The Supreme Court has set aside the Madhya Pradesh High Court’s Division Bench judgment and restored the promotion of an employee who was denied relaxation in educational qualifications despite being similarly placed as others.
The bench of Justice Prashant Kumar Mishra and Justice N.V. Anjaria has observed that the appellant belonged to the same class as other employees who were granted relaxation. Denial of similar benefit amounted to hostile discrimination. The principle of substantive equality must prevail in service matters.
The case arose from a dispute involving an employee of a Primary Agricultural Cooperative Society in Madhya Pradesh, who had over 28 years of service and was working as a Society Manager. His promotion was initially recommended by the Board of Directors and approved by the General Body of the Society, considering his long-standing experience and clean service record.
However, the Registrar rejected the proposal for relaxation in educational qualifications through a cryptic order, without assigning any reasons. This led to litigation, where the Single Judge of the High Court ruled in favour of the employee, but the Division Bench reversed that decision.
The Supreme Court examined whether denial of relaxation in educational qualifications to the appellant—while granting similar relaxation to other employees—amounted to arbitrary and discriminatory treatment in violation of constitutional guarantees.
The Court noted that two similarly situated employees had been granted relaxation and promoted, despite having the same educational qualifications as the appellant. This differential treatment, the Court held, lacked any rational basis.
“Discrimination is the other name of injustice,” the Court observed at the outset of its judgment.
The Court strongly criticized the Registrar’s decision, highlighting that the rejection order was non-speaking and cryptic. It failed to consider the recommendations of both the Board of Directors and the General Body. It ignored the fact that relaxation was expressly permissible under the applicable rules
The Court clarified that the power to grant relaxation was vested with the Board of Directors, and once exercised validly, the Registrar could not arbitrarily override it.
The Supreme Court held that the denial of equal treatment in promotion violated Articles 14 and 16 of the Constitution, which guarantee equality before law and equal opportunity in public employment.
The Division Bench of the High Court was faulted for adopting a contradictory approach. While it acknowledged that the power of relaxation lay with the Board, it still upheld the Registrar’s refusal.
The Supreme Court termed this reasoning as misdirected and unsustainable, noting that it overlooked both statutory provisions and factual parity.
The Court also took note of later developments the qualification requirements were revised again in 2019, lowering the threshold. The appellant subsequently acquired higher qualifications, including a postgraduate degree and computer diploma
These factors further reinforced that denial of promotion earlier was unjustified.
Allowing the appeals, the Supreme Court set aside the Division Bench judgment and review order, restored the findings of the Single Judge and upheld the appellant’s entitlement to promotion with relaxation
Case Details
Case Title: Kamal Prasad Dubey Versus The State Of Madhya Pradesh And Others
Citation: JURISHOUR-721-SC-2026
Case No.: SLP (C) Nos. 13578-13579 of 2020
Date: 10/04/2026
