Introduction:

In a pivotal judgment, the Kerala High Court has clarified that a candidate possessing a dual main degree from a recognized university is entitled to the advantages of both degrees. This decision came after the Kerala Public Service Commission (PSC) challenged the eligibility of a candidate with a double main degree—BA in Arabic and Islamic History from Calicut University—for a post requiring a degree in Arabic. The applicant, Aboobacker Mattayi, argued that his degree met the eligibility criteria for the advertised Full Time Junior Language Teacher Arabic-LPS position, despite having a degree in both Arabic and Islamic History. The PSC had initially rejected his application, stating that the inclusion of Islamic History as a secondary subject in the degree disqualified him from applying for the Arabic-specific role. The High Court, through its Division Bench of Justice A. Muhamed Mustaque and Justice P. Krishna Kumar, ruled in favour of the applicant, stating that a double main degree from a university equates to possessing both degrees individually, and therefore, the candidate was eligible to apply for the post.

Arguments of Both Sides:

Applicant’s Arguments:

The applicant, Aboobacker Mattayi, contended that his dual main degree from Calicut University should be considered equivalent to holding both a BA in Arabic and a BA in Islamic History. He argued that the inclusion of a second main subject (Islamic History) alongside Arabic in his degree did not diminish his qualification in Arabic. The applicant’s counsel emphasized that the university had recognized the double main degree as equivalent to two separate degrees, and therefore, he was eligible for the post as per the qualifications outlined in the PSC’s advertisement. The counsel for the applicant also referred to a government notification from November 25, 2010, which acknowledged that a triple main degree was equivalent to degrees in each subject. Additionally, the applicant’s legal team pointed out that universities are expert bodies, and their decisions regarding degree equivalency should be given precedence over administrative interpretations by the PSC.

Kerala Public Service Commission’s Arguments:

The Kerala Public Service Commission, represented by Standing Counsel P.C. Sasidharan, opposed the applicant’s eligibility, arguing that the inclusion of Islamic History as a second subject in the degree disqualified the applicant from being considered for the post of Junior Language Teacher in Arabic. The PSC contended that the degree in Arabic was diluted by the inclusion of another subject and therefore did not meet the requirement of possessing a specific degree in Arabic, as stipulated by the PSC’s guidelines for the position. The Commission maintained that the degree was a composite one and not a separate degree in Arabic, thus rendering the applicant ineligible for the post, which necessitated a degree in Arabic alone.

Court’s Judgment:

The Kerala High Court, in its judgment, sided with the applicant, stating that the BA degree in Arabic and Islamic History awarded by the University of Calicut was equivalent to two separate degrees—BA in Arabic and BA in Islamic History. The Division Bench of Justices A. Muhamed Mustaque and P. Krishna Kumar observed that the mere inclusion of an additional subject in a main degree should not negate the qualification in one of the subjects. The court emphasized that the University, as an expert body, had deemed the double main degree equivalent to a single degree in both Arabic and Islamic History. The judgment also cited a government notification issued in 2010, which recognized a triple main degree as being equivalent to degrees in each of the subjects included.

The court dismissed the Kerala Public Service Commission’s petition, stating that the applicant possessed a BA degree in Arabic as required for the position of Junior Language Teacher Arabic-LPS. It ruled that the dual nature of the degree did not affect the validity of the applicant’s qualification in Arabic, as both subjects were part of the core curriculum. The court noted that the university’s decision to award a dual main degree should take precedence over the PSC’s interpretation of the eligibility criteria. The court’s decision reflects a broader understanding that a university’s academic structure and qualifications should be recognized, especially when those qualifications are equated to separate degrees in practice.

Furthermore, the court held that the PSC’s interpretation was incorrect and that the inclusion of Islamic History in the degree did not diminish the applicant’s qualification in Arabic. It also pointed out that universities are the primary bodies responsible for determining the structure and equivalency of their degree programs, and their determinations should not be lightly disregarded by administrative bodies like the PSC.

The High Court’s judgment in favour of the applicant serves as a significant ruling for candidates with dual or multiple main degrees, clarifying that such degrees hold equivalent value to individual degrees when applying for posts that require specific qualifications.