Introduction:

In the case of Dr. Sangeetha Sriraam v. The Teachers Recruitment Board and Others, the Madras High Court ruled in favor of Dr. Sangeetha Sriraam, whose candidature for the post of Assistant Professor (Human Rights) was unfairly withheld due to her completion of a one-year LLM program. The Court emphasized that since the University Grants Commission (UGC) has approved the one-year LLM program, it cannot be deemed invalid for public employment purposes. Justice RN Manjula, presiding over the matter, directed the Teachers Recruitment Board (TRB) to include the petitioner’s name in the selection list and issue her appointment order.

Arguments:

Petitioner’s Arguments:

Dr. Sangeetha Sriraam challenged the provisional selection list published by the TRB, asserting that she was arbitrarily excluded despite securing the highest marks in the written examination (133/175). She contended that candidates with lower marks were included while her name was omitted without any prior notification that a two-year LLM was mandatory. She further argued that her one-year LLM program, being UGC-approved, qualified her for Ph.D. admission and should not be deemed invalid for public appointment.

State’s Arguments:

The State contended that the petitioner’s candidature was not considered because she had pursued a one-year LLM program rather than a two-year LLM, which they claimed was the required qualification for the post. The respondents maintained that the exclusion was justified based on this criterion.

Court’s Judgment:

The Madras High Court ruled in favor of Dr. Sangeetha Sriraam, emphasizing that the recruitment notification did not explicitly require a two-year LLM. The Court noted that the petitioner’s qualification met the prescribed eligibility criteria, which mandated a Master’s degree with at least 55% marks. Furthermore, the Court cited a prior ruling that recognized a one-year LLM for Ph.D. admission, asserting that the same principle should apply to public appointments. The judgment highlighted that arbitrary discrimination between equivalent courses without valid justification is impermissible. The Court held that the TRB acted unfairly in disqualifying the petitioner and directed the Board to include her in the selection list and issue her appointment order within a reasonable timeframe.