Introduction:

The Punjab and Haryana High Court recently delivered a significant verdict upholding the validity and equivalence of part-time B.Tech (Civil Engineering) degrees awarded by Deen Bandhu Chhotu Ram University of Science and Technology, Murthal, for promotion in government service. The decision came in a batch of intra-court appeals filed by junior engineers (JEs) of the Haryana State Government who challenged a single judge’s 2022 ruling that had invalidated their degrees. These JEs, initially appointed as diploma holders, enrolled in the university’s part-time B.Tech program after receiving departmental permission. The appeals were filed under the titles of Virender Kumar and others v. State of Haryana and others. The Division Bench, comprising Justice Sanjeev Prakash Sharma and Justice H.S. Grewal, examined the issue of recognition and equivalence of degrees awarded through weekend and evening classes, and considered relevant Supreme Court precedents, AICTE guidelines, and university approvals in delivering its judgment.

Arguments by the Petitioners:

The junior engineers argued that the part-time B.Tech courses they pursued were duly conducted by a recognised state university, with all necessary academic and executive approvals in place. The courses required physical attendance on campus, adherence to a full curriculum equivalent to regular engineering programs, and the involvement of qualified university faculty. They maintained that their degrees should be treated on par with regular degrees for all purposes, including promotions within the government service. The petitioners relied heavily on the university’s documentation and the AICTE’s 2020 public notification, which clarified that technical programs conducted with physical attendance in weekend/part-time or evening shifts qualify as regular courses. They contended that the single judge’s invalidation of their degrees was unfounded and detrimental to their career progression. The petitioners also pointed out that the State Government recognised these courses and encouraged employees to enhance their technical qualifications through such programs. They stressed that the program was residential and not a distance education course, as had been mistakenly suggested.

Arguments by the Respondents:

The State Government and AICTE representatives contended that the part-time courses did not hold the same value as full-time, regular B.Tech degrees and questioned the equivalence of such degrees for promotion purposes. They relied on earlier judicial precedents, which highlighted the need for scrutiny of the standards and quality of degrees awarded through non-regular courses. The respondents argued that such part-time or weekend courses might lack the rigour and comprehensive learning experience of regular courses, thereby warranting cautious acceptance in service matters. AICTE’s role in regulating technical education was also emphasised, although the university’s exemption from prior AICTE approval as a state university was acknowledged. The respondents sought to uphold the single judge’s ruling to prevent the dilution of qualification standards in government service.

Court’s Analysis and Judgment:

The Division Bench meticulously examined the nature and structure of the part-time B.Tech program. It noted that the course required physical attendance on campus for two days a week, followed the full curriculum prescribed for engineering degrees, and was taught by faculty members of the university itself. The bench emphasised that the program was residential and thus distinct from distance education courses. Highlighting the Supreme Court’s precedent in Dr. B.L. Asawa vs. State of Rajasthan (1982), the court observed that once a degree is awarded by a duly recognised institution, the question of its recognition and equivalence lies primarily with the employer unless a competent authority declares it invalid. The court underscored that it was not its role to question the quality or standards of the degree unless allegations of gross irregularity were made.

Further, the bench referenced the Supreme Court’s ruling in Bharathidasan University vs. AICTE (2001), which clarified that universities do not require AICTE approval to commence technical courses. It also recognised that the four-year part-time degree held parity with the three-year regular degree, based on course content, faculty, infrastructure, and teaching hours. The bench affirmed the AICTE’s 2020 notification that part-time/ weekend technical programs with physical attendance and adherence to the curriculum are to be treated as regular courses.

Given these considerations, the court held that the part-time B.Tech degrees awarded by the university must be treated as regular degrees for all service matters, including promotion. The bench thus set aside the single judge’s order and directed that appellants be considered duly qualified as per their seniority from the date persons junior to them were promoted, along with all consequential benefits. The judgment applauded the State Government’s progressive approach to enabling employees to upgrade their technical education while serving in government roles.

This verdict reinforces the principle that recognised part-time engineering degrees obtained through rigorous and physically attended programs hold equivalence to regular full-time degrees. It sends a positive signal to working professionals seeking to advance their qualifications without interrupting employment, ensuring fair recognition in service matters and career advancement. The judgment also emphasises judicial restraint in interfering with academic standards unless substantial irregularities surface, respecting the autonomy of universities and employers’ discretion in degree recognition.