Does a degree equivalence certificate take effect from the date of the degree or the Government Order?
Coram: Justice P.T. Asha
Service Law — Teacher recruitment — Equivalence of degrees — Government Order — Retrospective effect — Prospective operation — Judicial review — Service Law — Equivalence certificate — Effective from the date of the degree — Held: An equivalence certificate declaring one university's degree equivalent to another's takes effect from the date the university issued the degree, not from the date of the Government Order. Vested rights accrue on acquisition of the degree. (¶30) Service Law — Government Order withdrawing equivalence — Prospective operation only — Held further: A subsequent Government Order declaring a degree not equivalent operates prospectively alone and cannot unsettle equivalence already certified. Candidates whose degrees carried equivalence before the recruitment notification could not be rejected at certificate verification. (¶34, 33) Service Law — Syllabus similarity — Expert body's certificate not reopened — Held further: Once the equivalence committee has issued its certificate after comparing the syllabi, syllabus similarity cannot be reopened. Where equivalence is certified for the subject studied at either level, the same subject condition at UG and PG stands satisfied. (¶35, 36) Service Law — Judicial review in recruitment — Interference where a settled position is reinterpreted — Held further: Judicial review in recruitment is minimal, but interference is called for where a new interpretation is introduced upon a position already decided. The Government Order is quashed only for the subjects the petitioners applied for; writ petitions allowed. (¶37, 38)
Does a degree equivalence certificate take effect from the date of the degree or the Government Order?
From the date the university issued the degree. Where neither the equivalence committee nor the Government Order confines the validity of the degree to operate prospectively, the equivalence dates back to the date of issuance, and the vested rights created from the date of acquisition of the degree cannot be taken away.
Can a later Government Order declaring a degree not equivalent affect degrees obtained before it?
No. Such a Government Order can operate prospectively alone and cannot affect degrees obtained prior to its date where the equivalence had previously been certified either by a university or competent authority; equivalence already obtained cannot be declared not equivalent by virtue of the subsequent Government Order.
What did the Madras High Court decide on the Teachers Recruitment Board's equivalence rejections?
The writ petitions were allowed. Because quashing the entire Government Order would be counter productive, it was quashed only with reference to the subjects for which the respective petitioners had applied, and the connected miscellaneous petitions were closed with no costs.
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The sum and substance of the case of the petitioners is that the respective posts and the degree obtained by them is equivalent to the degree which is the educational qualification sought under the recruitment notification.
Since the point for consideration is common in all the writ petitions, I do not propose to extract the details set out in each petitions.
Some of the petitioners relied upon Government Orders prior to the date of notification and some subsequent to it and referred to in the notification itself. The common case of all the petitioners is that since they have obtained equivalence certificate they are eligible to be considered for appointment. However, their candidature has been rejected / overlooked and therefore the petitioners have approached this Court for the respective reliefs claimed by them.
The respondents on the other hand would contend that degrees obtained by the petitioners are not equivalent as per the extant rules / Government Orders as on date of the application. Therefore, their contention is that the writ petitioners cannot claim any right. Submissions:
Mrs. N.Kavitha Rameshwar, learned counsel appearing for petitioners in WP.Nos.28307 & 34207 of 2024, 1227, 16903 & 23853 of 2025, 3157, 3425, 4150 & 7346 of 2026, would submit that the Hon’ble Full Bench of this Court in the judgement reported in 2014 (3) CTC 433 – Nadar Thanga Shubha Laxman A Vs. State of Tamil Nadu, had held that where equivalence is granted by the committee it would date back and take effect from the date on which the candidate had obtained degree. However, in the case of non-equivalence the same should be applied prospectively i.e., from the date of the order. This is the dicta laid down by the Division Bench of this Court in the case of M.D.Ramya Vs. The State of Tamil Nadu in WA.No.166 of 2024 dated 12.07.2024.
These judgements have been followed by the succeeding single Judges as well as Division Benches and has more or less become the settled dicta. Therefore, once the degree obtained by the petitioner has been issued with equivalence certificate then the same would date back to the date of the degree. Therefore, the degrees obtained by the petitioners are deemed to be equivalent from the date of their acquiring the same.
The learned counsel would also submit that the issue of equivalence and the power of the Government in this regard is applicable only in respect of posts which are filled in consultation with the Public Service Commission under Section 25 of the Tamil Nadu Government Servants (Conditions of Service) Act, 2016. This cannot be stretched beyond the purpose for which it has been created particularly when the present case relates to NCTE notification, which has spelt out the eligibility criteria. Therefore, the Government is bound to adhere to the guidelines / criteria provided therein.
The learned counsel would also submit that the recruitment is for classes VI – VIII and the eligibility that required is graduation, B.Ed., and TET pass. She would also submit that insistence on qualification being treated equivalent to the course offered by the University of Madras is flawed in as much as there are several universities now offering courses and specialisations which are not being offered by the University of Madras. Therefore, the insistence on the qualification being equivalent to a course offered by the University of Madras is totally misdirected.
Mrs. Nalini Chidambaram, learned Senior Counsel appearing on behalf of Mrs. C.Uma, learned counsel for the petitioners in WP.Nos.6876, 7845 & 12013 of 2026 would in addition to the above submissions of Mrs.N.Kavitha Rameshwar contend that notification No.1/2023 dated 05.06.2023, has been issued by the Teachers Recruitment Board inviting applications for direct recruitment for eligible candidates for the post of Block Educational Officer in the Directorate of Elementary Education under the Tamil Nadu Elementary Education Subordinate Service for the years 2019 – 2020, 2021 – 2022 for the subject B.Sc., Botany. The equivalent GO is given in S.No.9, i.e., Micro Biology is equivalent to Botany / Zoology in GO.Ms.No.72, Higher Education (K2) Department dated 30.04.2013. Such being the case the degree obtained by the petitioners fall within this GO.
This has been replicated in notification No.3/2023 dated 25.10.2023, wherein applications were invited for direct recruitment of Graduate Teachers / Block Resource Teacher Educators (BRTE) in school education and other departments included in the Special Rules for the Tamil Nadu School Education Subordinate Service for the year 2023 – 2024.
Therefore, it is her contention that even as per the very notification of the Teachers Recruitment Board, the degree in Micro Biology is equivalent both for Botany as well as Zoology. After having issued the above notification, the respondents are estopped from contending that candidates who have secured a degree in Micro Biology are ineligible to teach Botany / Zoology in Schools.
The learned Senior Counsel would submit that once GO.Ms.No.72 provides equivalence for a degree in Micro Biology to Botany and Zoology, the subsequent GO.Ms.No.170, dated 24.09.2024, cannot cancel the equivalence granted by the earlier GO since once equivalence is granted it dates back to the date of degree, whereas, the Government Order denying the equivalence operates prospectively.
The learned Senior Counsel would also submit that the petitioner in WP.No.6876 of 2026 had secured BBA in the year 1998 from the Madras University. The syllabus for BBA covers a wide spectrum of courses like Commerce, Principles of Management, Financial and Management Accounting etc., The petitioner had also secured PG degree in Commerce from Annamalai University and B.Ed degree from Tamil Nadu Teachers Education University in the year 2014. She had applied for the post of PG Assistant in the subject Commerce. The educational qualification for the said post was as follows:
“(i)Post Graduate with at least 50% marks from a recognised university. (ii)B.Ed from National Council for Teacher Education recognized institution. (iii)The candidate must have obtained Bachelor’s degree and Master’s degree in the same subject.”
As per GO.Ms.No.72, the equivalence committee had resolved to grant equivalence for M.Com as M.Com with BBA. Therefore, when the petitioner had applied for the post she had equivalent degree and the subsequent GOs will not effect the degree already obtained by the petitioner. Therefore, she would pray that the writ petitions be allowed.
Mr. N.A.Nissar Ahmed, learned Senior Counsel appearing on behalf of Mr.Umapathy, learned counsel for the petitioners in WP.Nos.3006 & 3009 of 2026 would also rely upon the judgement of the Full Bench in the case of Nadar Thanga Subalakshman referred supra. The learned Senior Counsel has drawn the Court’s attention to the Reference made to the Full Bench in the said judgement and the ultimate answer given to it by the Full Bench. He would also submit that the GOs granting equivalence to the subjects in which the petitioners had obtained their respective degrees cannot be superseded by subsequent GO, since earlier order granting equivalence automatically dates back to the date of the grant of the degree.
Mrs. Dhakshyani Reddy, learned Senior Counsel appearing on behalf of Mrs.S.Suneetha, learned counsel for the petitioner in WP.No.7056 of 2026 would add that there were several courses that the University of Madras did not provide which is provided by other universities. Further, GO.Ms.No.72 has not been nullified / cancelled by the subsequent GOs. Therefore, the impugned order has to necessarily be quashed.
Mr.C.Kathiravan, learned Standing Counsel for the Teachers Recruitment Board in his written submissions would submit that the relief claimed by the petitioners cannot be granted since during the certificate verification of the petitioners it was found that their respective degrees cannot be considered as equivalent to the degree prescribed for the post applied. He would submit that as per notification No.2/2025, the qualification criteria was that the candidates must have studied UG and PG in equivalent subjects. He would rely upon clause 11 (3) of the said notification, which reads as follows:
“11.QUALIFICATION CRITERIA iii.As per GO.Ms.No.361, School Education Department dated 31.12.1999, candidates should have studied the same subject or its equivalent subject in Bachelor’s Degree and Master’s Degree.”
He would submit that it is the Higher Education Department which is the competent authority in determining equivalence and the board was not vested to act its own accord and they would only rely upon GO that was in force at the time of the certificate verification. He would further submit that the impugned notification has not been challenged by the petitioners.
He would rely upon the judgement of the Hon’ble Supreme Court reported in 2026 SCC Online 88 – Md. Firoz Mansuri and others Vs. State of Bihar, which was a case relating to similar challenge for prescription of qualification for public posts based on nature of duties, administrative needs and policy considerations. The Hon’ble Supreme Court held that the courts had a very limited judicial review in such matters.
He would submit that there was no repugnancy between rules prescribed by NCTE and the state recruitment rules. The prescription of the specific degree for the post of teachers was one based on the subject specific knowledge, teaching methodology and educational standards required at school level. It would not be in the interest of students to employ candidates holding different degrees to teach students in respect of other subjects. He would further submit that the Teachers Recruitment Board has acted well within its powers and the grievance expressed by the petitioners is totally misconceived.
Mr. A.R.Balaji, learned Government Advocate appearing for the State would contend that the recognition of the equivalent qualification requires the declaration by the Government. Such a declaration is made only after an expert body, namely, equivalence committee after following a detailed procedure and ultimately declares a particular degree qualification to be either equivalent or non equivalent. The Government merely declares this conclusion of the equivalence committee.
He would also contend that the Government Order merely recognizes an existing qualification as equivalent to another qualification for administrative purposes after expert academic evaluation. He would further submit that the equivalence will operate prospectively from the date of issuance of the Government Order would be arbitrary and would defeat the very purpose of equivalence determination and create artificial distinctions among similarly situated candidates.
The learned Government Advocate would further submit that in the 55th Equivalence Committee meeting held on 02.08.2017, the committee evolved a benchmark whereby equivalence would be considered where there is approximately 75% similarity in the syllabus between course undergone by the candidate and the post for which applications are invited. He would also urge that judicial review should be minimal particularly when each of the GOs have been issued after the expert body has arrived at their conclusion after indepth analysis. He would rely upon the judgement of the Hon’ble Supreme Court reported in 2019 (6) SCC 362 – Maharashtra Public Service Commission Vs. Sandeep Shriram Warade in support of his argument with reference to judicial review.
He would also submit that the writ petitions cannot be heard and decided uniformly as the writ petitions relate to multiple educational qualifications awarded by different universities. He would submit that equivalence determination is course-specific, syllabus-specific and university-specific. Different Universities offer different curricula and therefore, all the petitioners cannot be treated as a homogeneous class. He would further argue that GO.Ms.No.72 relates to several subjects and only few of the subjects covered under the said GO relate to the petitioners. Therefore, striking of the entire GO is highly erroneous.
The learned Government Advocate would further argue that the respective degrees of the petitioners should atleast have 51% syllabus similarity to the post for which they have applied. It is only the expert body which can look into the same and the Courts cannot enter into the filed which exclusively remains with the expert body.
He would submit that the procedure adopted by the respondents is totally transparent and based on the expert academic evaluation. The GOs are mere consequential orders based on the recommendation of the expert body. The petitioners have not established any violation of Section 25 of the Tamil Nadu Government Servants (Conditions of Service) Act 2016. He therefore sought for dismissal of the writ petitions.
The writ and details of the petitioners, degree obtained by them, the GOs showing equivalence with date and the GO relied upon by the respondents to render the petitioners ineligibility is set out herein below:
Sl. No — WP No./ petitioners’ name — Post Applied for — Degree obtained — GO.NO:. forming basis for Equivalence — Equivalence for which subject — GO.NO: forming basis for Non-Equivalence — Subject Non-Equivalence for 1. WP 3006 of 2026 Priya Durga — P. G Assistant (Botany) — 1. B.Sc. Microbiology Bharathidasan University. 2. M.Sc. Microbiology Bharathidasan University. 3. B.Ed. – TN Teachers Education University. — G.0 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — G.0 170 dt. 24.09.2024 GO.NO: 233 dt. 06.10.2025 — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology and M.Sc. Botany. 2. WP 3009 of 2026 Vinothini — P. G Assistant (Zoology) — 1. B.Sc. Microbiology University of Madras (2005). 2. M.Sc. Applied Microbiology Periyar University (2007). 3. B.Ed. – TN Teachers Education University. — G.0 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 111 dt. 17.04.2 023. GO.NO: 66 dt. 24.04.2019 — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. M.Sc. Applied Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 3. WP 28307 & 23853 of 2025 K. Rajendran — B.T.Assistant (History) — 1. B.A. (History, Economy & Political Science ) Sri Venkateswara University (1994). 2. B.Ed. Sri Venkateswara University (2008). 3.M.A.(History) Alagappa University (2015). — GO.NO: 316 dt.27.01.2026 — B.A from Sri Venkateswara University is EQUIVALENT to B.A.History. — GO.NO:. 34 dt 15.02.2021 GO.NO: 100 dt. 29.05.2025 — B.A. obtained from Sri Venkateswara University is NOT EQUIVALENT to BA (Political Science). B.A.(History, Economy & Political Science) from Sri Venkateswara University is NOT EQUIVALENT to B.A.History. 4. WP 34207 of 2024 M. Mani — B.T.Assistant (Zoology) — 1.B.Sc. Zoology, Madurai Kamaraj University (2009). 2.M.Sc. Zoology, Madurai Kamaraj University (2011). 3. B.Ed. – TN Teachers Education University. (2013) — GO.NO: 58 dt01.03.2016 — B.Sc. Zoology (Vocational) / Industrial Microbiology) from Periyar University, Salem is EQUIVALENT to B.Sc. Zoology. — GO.NO:. 179 dt. 07.10.2024 — B.Sc. Zoology (Vocational) / Industrial Microbiology) from Madurai Kamaraj University is NOT EQUIVALENT to B.Sc. Zoology. 5. WP 3157 of 2026 S. Vaishnavi — P. G Assistant (Zoology) — 1. B.Sc. Biotechnology, Bharathiar University(2009). 2. M.Sc. Biotechnology, Bharathiar University(2011). 3. B.Ed. Biological Science, TN Teacher Education University (2022). — GO.NO:104 dt. 22.06.2012. G.0 72 dt.30.04.2013 — B.Sc.(Animal Science & Biotechnolog y) and B.Sc. (Advanced Zoology & Biotechnolog y) is EQUIVALENT to B.Sc. Zoology. Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 124 dt.25.06.2018 GO.NO :.111 dt.17.04.2023 — B.Sc. Biotechnology from Bharathiar University NOT EQUIVALENT to B.Sc. Zoology. M.Sc. Biotechnology from Bharathiar University is NOT EQUIVALENT to M.Sc. Zoology. 6. WP 3243 of 2026 P. Karthikeyan — P. G Assistant (Zoology) — 1.B.Sc. Microbiology Bharathidasan University (2009). 2. M.Sc. Microbiology Bharathidasan University (2011). — G.0 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 170 dt. 24.09.2024 GO.NO: 233 dt. 06.10.2025 — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology and M.Sc. Botany 7. WP 3280 of 2026 S. Anantha Jothi — P. G Assistant (Botany) — 1.B.Sc. Microbiology Madurai Kamaraj University (2006). 2. M.Sc. Microbiology, Bharathidasan University (2008). — G.0 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 233 dt. 06.10.2 025. — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology and M.Sc. Botany. 8. WP 3272 of 2026 M.Haseena — P. G Assistant (Botany) — 1. B.Sc. Microbiology University of Madras (2006) 2. M.Sc. Microbiology University of Madras (2008) — GO.NO: 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 136 dt. 26.06.2 025. GO.NO: 36 dt. 15.02.2023 — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Botany. 9. WP 3262 of 2026 J. Lourdhu Jeniva — P. G Assistant (Zoology) — 1. B.Sc. Zoology Manonmani Sundaramnar University (2007). 2. M.Sc. Microbiology Madurai Kamaraj University (2009). — GO.NO: 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 66 dt. 24.04.2019 — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 10. WP 3254 of 2026 A. Suganthi — P. G Assistant (Botany) — 1. B.Sc. Microbiology Bharathidasan University (2010). 2. M.Sc. Microbiology Bharathidasan University (2012). — GO.NO: 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 72 dt. 15.03.2024 GO.NO:. 233 dt 06.10.2025 — B.Sc. Microbiology NOT EQUIVALENT to Botany M.Sc. Microbiology NOT EQUIVALENT to Botany 11. WP 3425 of 2026 C. Chelva Chaundarya Devi — P. G Assistant (Physics) — 1. B.Sc. Botany (Special Education Rehabilitation), Avinashlingam University for Women (2007). — GO.NO:.52 dt31.01.1996 — BA., B.Sc., B.Ed., M.A., M.Sc., MCA., M.Ed., M.Phil. and Ph.D. degree courses from Avinashilingam Institute for Home Science and Higher Education for Women be recognised for Public Employment. — GO.NO :36 dt. 15.02.2 023, — B.Sc. Botany (Special Education Rehabilitation) from Avinashlingam University for Women is NOT EQUIVALENT to B.Sc. Physics. 12. WP 4150 of 2026 S. Vaishnavi — P. G Assistant (Zoology) — 1.B.Sc Biotechnology, Bharathiar University(2009). 2. M.Sc. Biotechnology, Bharathiar University(2011). 3.B.Ed.Biological Science TN teachers education University (2022). — GO.No:104, dt.22.06.2012 GO.No:169 dt.26.06.2019 — B.Sc. Biotechnology & Zoology is EQUIVALENT to B.Sc. Zoology. Advanced Biology, Biotechnology, Plant Biology and Plant Biotechnology is EQUIVALENT to Biological Science. — GO.No.124 dt 25.06.2018 GO. No: 111 dt. 17.04.2023 — B.Sc. Biotechnology from Bharathiar University is NOT EQUIVALENT to B.Sc. Zoology. M.Sc. Biotechnology from Bharathiar University is NOT EQUIVALENT to M.Sc. Biotechnology. 13. WP 1227 & 16903 of 2025 M. Palanikumar — Post of Junior Analyst — 1. B.Sc. Microbiology, Manonmanian Sundaranar University(2003). 2.M.Sc. Immunology and Microbiology, Madurai Kamaraj University (2006). 3.M.Phil. Microbiology, Bharathidasan University (2007). — GO.NO: 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — GO.NO: 111 dt. 17.04.2 023. — M.Sc. (Immunology and Microbiology) from by Madurai Kamaraj University is NOT EQUIVALENT to M.Sc. Microbiology. 14. WP 4702 of 2026 T. Kalpana — P. G Assistant (Economics) — 1. B.A.Economics Annamalai University (2006) 2. M.A.Business Economics Annamalai University (2008) — GO.NO: 72 dt.30.04.2013 — M.A.Business Economics is EQUIVALENT to M.A. Economics. — GO.NO: 267 dt 29.11.2019 — M.A.Business Economics IS NOT EQUILVALENT to M.A.Economics 15. WP 6170 of 2026 Revathi — P. G Assistant (Commerce) — 1. B.Com Bharathiar University (2006) 2. M.Com International Business Bharathiar University (2008) 3. B.Ed. TN Teachers Education University (2020) — GO.NO: 72 dt.30.04.2013 — M.Com International Business is EQUIVALENT to M.Com — GO.NO :195 dt 14.08.2019 — M.Com International Business is NOT EQUIVALENT to M.Com 16. WP 6876 of 2026 R. Brindha — PG Assistant (Commerce) — 1.Bachelor of Business Administration- Madras University (1998) 2. Degree of Master of Commerce – Annamalai University (2000). 3. B.Ed. – TN Teachers Education University (2014) — GO.NO: 72 dt.30.04.2013 GO.NO: 215 dt31.08.1998 — M.Com with BBA EQUIVALENT to M.Com M.Com with BBA to M.Com is EQUIVALENT — GO: NA Provisi onal Selecti on List dt. 22.01.2026 — Withheld for want of Equivalence as per notification. 17. WP 7056 of 2026 R. Rajeshwari — PG Assistant (Chemistry) — 1.B.Sc. Chemistry- Avinashilingam institute for Home Science and Higher Education for Women (Deemed) University- (2003) 2. M.Sc. Chemistry- Periyar University (2005) 3. B.Ed.- Bharathiar University (2007) — GO.NO: 52 dt31.01.1996 GO.NO:.10 2 dt16.06.2026 — All qualifications obtained from Avinashilingam University as EQUIVALE NT. B.Sc. Chemistry and Physics is EQUIVALENT to B.Sc. Chemistry — GO.NO: 43 dt 11.02.2026 — B.Sc. Chemistry from Avinashilingam University is NOT EQUIVALENT to B.Sc. Chemistry 18. WP 7346 of 2026 M. Kavikkuil — BT Assistant/ PG Assistant (Botany). — 1.B.Sc. (Biotechnology), Seethalaskhmi Ramaswami (Autonomous) University (2011). 2. M.Sc. Biotechnology (2013). 3. B.Ed. TN Teachers Education University (2022) — GO.NO: 72 dt. 30.04.2013. — B.Sc. Plant Biotechnology is EQUIVALENT to B.Sc. Botany — GO.NO :.4 dt 08.01.2 025. — B.Sc. Biotechnology awarded by Seethalakshmi Ramaswami (Autonomous) University affiliated to Bharathidasan University IS NOT EQUIVALENT to B.Sc. Zoology. Likewise, M.Sc. Biotechnology awarded by Alagappa University was NOT EQUIVALENT to M.Sc. Botany. 19. WP 7845 of 2026 S. Saranya — P. G Assistant (Zoology) — 1. B.Sc. Microbiology Bharathidasan University (2008). 2. M.Sc. Microbiology Sastra University (2010). 3. B.Ed. – TN Teachers Education University (2021) — G.0 72 dt.30.04.2013 — Microbiology is EQUIVALENT to Botany and Zoology. — G.0 170 dt. 24.09.2024 — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology 20. WP.No.12013 of 2026 P.Charulatha — B.Sc. Microbiology (UG), University of Madras (2003). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.11 1, dt.17.04.2023 (Serial No.44) G.O.M s.No.13 6, dt.26.06.2025 (Serial No.10, Item No.27) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. 21. WP.No.12013 of 2026 M.Manimozhi — B.Sc. Microbiology (UG), University of Madras (2004). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.11 1, dt.17.04.2023 (Serial No.44) G.O.M s.No.13 6, dt.26.06.2025 (Serial No.10, Item No.27) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. 22. WP.No.12013 of 2026 K.Muniappan — B.Sc. Microbiology (UG), Bharathidasan University (2009). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 23. WP.No.12013 of 2026 S.Chinnadurai — B.Sc. Microbiology (UG), Periyar University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 24. WP.No.12013 of 2026 M.Agilan — B.Sc. Microbiology (UG), Bharathidasan University (2009). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 25. WP.No.12013 of 2026 D.Ezhilan — B.Sc. Microbiology (UG), Bharathidasan University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 26. WP.No.12013 of 2026 S.Thameemunisa — B.Sc. Microbiology (UG), Thiruvalluvar University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.17 0, dt.24.09.2024 (Serial No.11, Item No.20) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 27. WP.No.12013 of 2026 S.Elavarasi — B.Sc. Microbiology (UG), University of Madras (2003). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.11 1, dt.17.04.2023 (Serial No.44) G.O.M s.No.13 6, dt.26.06.2025 (Serial No.10, Item No.27) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. 28. WP.No.12013 of 2026 R.Vani Rani — B.Sc. Microbiology (UG), Bharathidasan University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 29. WP.No.12013 of 2026 R.Muthuselvi — B.Sc. Microbiology (UG), Madurai Kamaraj University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.2, Serial No.26) G.O.M s.No.10 0, dt.29.05.2025 (Serial No.2, Item No.4) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 30. WP.No.12013 of 2026 V.Jansidevi — B.Sc. Microbiology (UG), Madurai Kamaraj University (2004). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.2, Serial No.26) G.O.M s.No.10 0, dt.29.05.2025 (Serial No.2, Item No.4) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 31. WP.No.12013 of 2026 S.Indira — B.Sc. Microbiology (UG), Madurai Kamaraj University (2005). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.2, Serial No.26) G.O.M s.No.10 0, dt.29.05.2025 (Serial No.2, Item No.4) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 32. WP.No.12013 of 2026 K.Anbukkarasi — B.Sc. Microbiology (UG), Bharathidasan University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 33. WP.No.12013 of 2026 R.Sugapriya — B.Sc. Microbiology (UG), Periyar University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 34. WP.No.12013 of 2026 T.Jancy Jasmine — B.Sc. Microbiology (UG), University of Madras (2009). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.11 1, dt.17.04.2023 (Serial No.44) G.O.M s.No.13 6, dt.26.06.2025 (Serial No.10, Item No.27) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. 35. WP.No.12013 of 2026 R.Sheeba Jansi Rani — B.Sc. Microbiology (UG), University of Madras (2009). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.11 1, dt.17.04.2023 (Serial No.44) G.O.M s.No.13 6, dt.26.06.2025 (Serial No.10, Item No.27) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. 36. WP.No.12013 of 2026 V.Vidhya Lakshmi — B.Sc. Microbiology (UG), Bharathidasan University (2004). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 37. WP.No.12013 of 2026 S.Jaya Lakshmi — B.Sc. Microbiology (UG), Bharathidasan University (2002). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 38. WP.No.12013 of 2026 S.Saranya — M.Sc. Microbiology (PG), Sastra University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 39. WP.No.12013 of 2026 T.Nathiya — B.Sc. Microbiology (UG), Bharathiar University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 40. WP.No.12013 of 2026 S.Amalajothi — B.Sc. Microbiology (UG), Alagappa University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 41. WP.No.12013 of 2026 R.Nathiya — B.Sc. Microbiology (UG), Periyar University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 42. WP.No.12013 of 2026 S.Sangeetha — M.Sc. Microbiology (PG), Bharathidasan University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.23 3, dt.06.10.2025 (Serial No.8, Item No.24) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Botany. 43. WP.No.12013 of 2026 T.Chithra — B.Sc. Microbiology (UG), Manonmaniam Sundaranar University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 44. WP.No.12013 of 2026 M.Raja Lakshmi — B.Sc. Microbiology (UG), Thiruvalluvar University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.17 0, dt.24.09.2024 (Serial No.11, Item No.20) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 45. WP.No.12013 of 2026 S.Radhiga — B.Sc. Microbiology (UG), Thiruvalluvar University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.17 0, dt.24.09.2024 (Serial No.11, Item No.20) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 46. WP.No.12013 of 2026 M.Tamil Selvi — B.Sc. Microbiology (UG), Thiruvalluvar University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.17 0, dt.24.09.2024 (Serial No.11, Item No.20) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 47. WP.No.12013 of 2026 D.Hancy Udhaya Kumari — B.Sc. Microbiology (UG), Periyar University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 48. WP.No.12013 of 2026 C.Deepa — M.Sc. Microbiology (PG), Periyar University (2012). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.66 , dt.24.04.2019 (Agenda No.2(iii )) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 49. WP.No.12013 of 2026 G.Indira — M.Sc. Microbiology (PG), Periyar University (2012). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.66 , dt.24.04.2019 (Agenda No.2(iii )) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 50. WP.No.12013 of 2026 A.Umadevi — M.Sc. Microbiology (PG), Periyar University (2012). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.66 , dt.24.04.2019 (Agenda No.2(iii )) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 51. WP.No.12013 of 2026 V.Kavitha — B.Sc. Microbiology (UG), Bharathidasan University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 52. WP.No.12013 of 2026 R.Suganya — M.Sc. Microbiology (PG), Bharathidasan University (2013). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.23 3, dt.06.10.2025 (Serial No.8, Item No.24) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Botany. 53. WP.No.12013 of 2026 K.Asha — M.Sc. Microbiology (PG), Manonmaniam Sundaranar University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.16 9, dt.26.08.2022 (Item No.15) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 54. WP.No.12013 of 2026 K.Sivaveni — M.Sc. Microbiology (PG), Periyar University (2020). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.66 , dt.24.04.2019 (Agenda No.2(iii )) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 55. WP.No.12013 of 2026 R.Sujithra — B.Sc. Microbiology (UG), Bharathiar University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 56. WP.No.12013 of 2026 V.Jayanthi — B.Sc. Microbiology (UG), Bharathidasan University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 57. WP.No.12013 of 2026 R.Raja Lakshmi — B.Sc. Microbiology (UG), Periyar University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 58. WP.No.12013 of 2026 S.Ramya Thangam — B.Sc. Microbiology (UG), Periyar University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 59. WP.No.12013 of 2026 R.G.Amudha — B.Sc. Microbiology (UG), Periyar University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 60. WP.No.12013 of 2026 R.Sathya — B.Sc. Microbiology (UG), Periyar University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.56 , dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 61. WP.No.12013 of 2026 V.Indumathi — M.Sc. Microbiology (PG), Bharathidasan University (2006). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.23 3, dt.06.10.2025 (Serial No.8, Item No.24) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Botany. 62. WP.No.12013 of 2026 G.Alamelu Mangai — M.Sc. Microbiology (PG), Periyar University (2016). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.66 , dt.24.04.2019 (Agenda No.2(iii )) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Zoology. 63. WP.No.12013 of 2026 D.Jothi Lakshmi — B.Sc. Microbiology (UG), Manonmaniam Sundaranar University(2009). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 64. WP.No.12013 of 2026 K.Pushpa — M.Sc. Applied Microbiology (PG), Thiruvalluvar University (2011). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 65. WP.No.12013 of 2026 T.Suganya — B.Sc. Microbiology (UG), Bharathidasan University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.72 , dt.15.03.2024 (Item No.3, Serial No.27) G.O.M s.No.17 0, dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 66. WP.No.12013 of 2026 B.Saranya — M.Sc. Microbiology (PG), Bharathidasan University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.M s.No.23 3, dt.06.10.2025 (Serial No.8, Item No.24) — M.Sc. Microbiology is NOT EQUIVALENT to M.Sc. Botany. 67. WP.No.12013 of 2026 S.Packiaya Mary — M.Sc. Microbiology (PG), Mother Teresa Women's University (2008). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — — — — 68. WP.No.12013 of 2026 S.Menaka — B.Sc. Microbiology (UG), Bharathidasan University (2005). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.Ms.No.72, dt.15.03.2024 (Item No.3, Serial No.27) G.O.Ms.No.170 , dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 69. WP.No.12013 of 2026 B.Jansirani — B.Sc. Microbiology (UG), Bharathidasan University (2009). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.Ms.No.72, dt.15.03.2024 (Item No.3, Serial No.27) G.O.Ms.No.170 , dt.24.09.2024 (Serial No.7, Item No.16) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Botany. B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology. 70. WP.No.12013 of 2026 M.Chitra — B.Sc. Microbiology (UG), Periyar University (2007). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.Ms.No.56, dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany. 71. WP.No.12013 of 2026 Jenifer.P — B.Sc. Microbiology (UG), Periyar University (2010). — G.O.Ms.No.72, dt.30.04.2013 — Yes — Equivalent — G.O.Ms.No.56, dt.15.03.2018 (Agenda No.6) — B.Sc. Microbiology is NOT EQUIVALENT to B.Sc. Zoology / B.Sc. Botany.
The above table would show that the degrees obtained by the respective petitioners have been declared equivalent prior to the TRB notification. The Full Bench of this Court in the judgement in Nadar Thanga Shubha Laxman supra was called upon to answer the following questions: "Whether the Equivalence Certificate issued by the Committee constituted by the Government, declaring that the degree obtained from one University is equivalent to the degree obtained from yet another University is only prospective in operation and whether the view taken by the Division Bench of this Court in N.Geetha's case is correct?"
The learned Judges had observed as follows in paragraph No.14: “The learned Division Bench, in its brief order, while dealing with the qualification namely, M.Sc., Mathematical Economics declared as equivalent to M.A. Economics degree by the Government in G.O.Ms.No.72, Higher Education (K2), Department, dated 30.04.2013, as per the recommendation of the Equivalence Committee, was of the view that, if any selection is made for teacher appointment after G.O.Ms.No.72, Higher Education (K2), Department dated 30.04.2013 which holds certain degrees equivalent to other degrees issued by some other educational institutions, such candidates become qualified from the date of such Government Order. Pausing here, straight away, we intend to observe that such a tight and narrow view to hold a particular degree as equivalent to another degree only from the date of the G.O. will unjustly take away the rights accrued from the date of acquisition of the degree, therefore, when there is no such specific mention made by the Government Order or the Equivalence Committee about the prospective or retrospective effect of the degree already obtained, giving prospective effect by reducing/curtailing the validity of the degree certificate is totally uncalled for. As a matter of fact, once the Equivalence Committee, after proper deliberations, have come to the conclusion that one degree issued by one university is equivalent to another degree issued by another university, it does not become equivalent to the other only from the date of issuance of the Government Order by the Government or on the date of Equivalence Committee considered it as equivalent, rather, it becomes equivalent from the very date of its issuance by the University concerned.
The Full Bench had therefore clearly observed that once the equivalence committee comes to the conclusion that one degree offered by one university is equivalent to the degree offered by the other, by virtue of such declaration, the degree would become equivalent from the very day on which it was issued by the university concerned, i.e., the equivalence becomes effective retrospectively.
The Bench had also given its reasoning for observing so in paragraph No.17 of the said judgement as follows: “17. A mere perusal of the above observation vividly shows that the candidates, who had appeared for TET with the requisite qualification as per the advertisement, have acquired vested rights and benefits, hence, the same cannot be retrospectively taken away, since this will visit civil consequences.
Ultimately, the Bench concluded as follows: “23. Also, in the present case, neither the Equivalence Committee nor the Government Orders in G.O.Ms.Nos.72, dated 30.04.2013 and 117, dated 02.07.2013, confined the validity of the degree obtained by the candidates to operate prospectively, therefore, as per the above judgments, when the vested rights are created from the date of their acquisition of equivalent degrees, the respondents cannot take a stand that the degrees obtained by the petitioners will only have prospective effect from the date of issuance of Equivalence Certificate. When both the Equivalence Committee and the Government Order have consistently not mentioned the effect of the validity of the degree, it is not proper to hold prospective by any one, more so, by the Court. That apart, a degree or a certificate issued by any University or competent educational authorities always have the effect on par with a decree issued by a competent civil court. Besides, it is well settled legal position that even an executing court cannot go behind its decree and this principle will mutatis mutandis undoubtedly apply to the case on hand as well. ……. 25. In view of the above settled position and for the foregoing reasons, we hold that the equivalence certificate issued by the committee constituted by the Government declaring that the degrees obtained from one University is equivalent to the degrees obtained from yet another University cannot be held to be only prospective in operation but will have its effect and validity right from the date of issuance, therefore, with due respect to the Hon'ble Division Bench, the view taken in N.Geetha's case is incorrect. Accordingly, the reference is answered.
The petitioners have also relied upon the judgement of the Division Bench of this Court reported in 2024 SCC Online Madras 3278 – M.D.Ramya Vs. State of Tamil Nadu in support of their argument that GO taking away equivalence will only operate prospectively. The Division Bench was considering a case where a degree which is originally found to be equivalent by subsequent GO was sought to be rendered not equivalent. The Division Bench after considering the facts of the case and the law in the subject and the various judgements on the subject discussed as follows: “16. The basis on which the Full Bench proceeded is that when the equivalence committee had held that the degrees are equivalent, and if such recommendations are given only prospective effect it would mean that the vested rights created from the date of acquisition of the degrees, would be taken away. Applying the very same logic, and also noting that a degree issued by a university is to be treated on par with a decree of a competent court, it certainly creates vested rights in the candidate. Moreso, in the present case, when the university already certified the equivalence during the relevant point in time, the State Government cannot nullify such equivalence at this distance of time by giving its recommendations retrospective effect. As such, the impugned order can operate prospectively alone and cannot affect degrees obtained prior to the date of the impugned order if the equivalence have been previously certified either by a university or competent authority. We find force in the submission of the counsel for the appellant that non-equivalence orders issued much later in time cannot be deemed to be retrospective and must only be prospective in nature so as not to take away the rights of candidates like the appellant who had acquired the said degree as early as in 2012 when the same was treated as equivalent to B.Sc. (Physics) and she was also granted admission to M.Sc. (Physics) based on such equivalence. 17. It is true that this Court, in exercise of powers under Article 226 of the Constitution of India, cannot interfere with the opinion rendered by the experts in the field. This Court is also not going into the correctness or otherwise of such opinion rendered by the experts. But at the same time, the order issued in G.O. Ms. No.244, Higher Education (C2) Department dated 07.11.2022, based on the opinion rendered by the experts, should not be put against the appellant to invalidate the otherwise valid degree obtained by her during the year 2012. In fact, the second respondent University itself has given equivalence certificate in favour of the appellant, based on which she participated in the competitive examination for the purpose of employment in public services. Therefore, we are of the view that the opinion rendered by the experts on 20.10.2022, based on which the Government issued G.O. Ms. No.244, Higher Education (C2) Department dated 07.11.2022, cannot be put against the appellant to deny her public employment. If at all, the Government Order in G.O. Ms. No.244, Higher Education (C2) Department dated 07.11.2022 must be applied prospectively and not retrospectively to bring within its sweep the degrees obtained by the students prior to the issuance of the said Government Order.”
In view of the above discussion, the equivalence already obtained by the petitioners cannot be declared as not equivalent by virtue of the subsequent GO. The Judgement reported in 2016 SCC Online Mad 15412 – R.Arumugam Vs. The Principal Secretary to Government and the unreported Judgement in R.Ghunasekaran Vs. The Government of Tamil Nadu, and others in Rev.Aplc.No.18 of 2020 dated 16.07.2024 does not differ from the order of the Full Bench. Therefore, the same cannot be canvased by the respondents to support their contention.
The argument that the equivalence should be decided by taking into consideration the similarity in the syllabus taught is a new argument that is sought to be made. Once the equivalence granted dates back to the date of the degree the equivalence committee while considering the issue of one degree being equivalent to the other has to necessarily compare the two on the basis of the syllabi offered by each as curriculum is one of the main criteria for granting equivalence. Once the said certificate has been so issued the same cannot be ignored. Therefore, this argument on the side of the respondents has to be negatived.
The further argument that the qualification criteria prescribed is that the candidate should have studied UG and PG in the same subject cannot be countenanced for the reason that once the equivalence certificate is issued in respect of the subject studied either in the UG or PG course then this condition stands satisfied.
There is no quarrel on the submission that judicial review should be minimal in the case of recruitment. However, where a new interpretation is sought to be introduced with reference to a position which is already decided, in such cases judicial interference is necessarily called for. However, considering the argument of the learned Government Advocate that the GO which is now subject matter of challenge deals with different subjects and therefore quashing the entire GO would be counter productive is a justifiable argument, therefore, the GO is quashed only with reference to related subjects for which the respective petitioners have applied for.
With the above observation, these writ petitions are allowed. Consequently, the connected miscellaneous petitions are closed. No costs.
Note: The Registry is directed to type the full cause title, if necessary while issuing the order copy.
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Whether a registered settlement deed reserving a life interest is a Will merely because possession is postponed?
AS.550/2023 · Madras High Court
Whether the High Court, in exercise of certiorari jurisdiction, was justified in interfering with the orders passed by the Arbitrator and the Tribunal or whether it exceeded its jurisdiction in doing so?
2026 INSC 927 · Supreme Court of India
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