Laxmikant Sharma vs State Of Madhya Pradesh 2025 INSC 1385 - Public Employment - Equivalence - Qualification
Constitution of India - Article 14, 226 -Public Employment - The question whether a particular qualification is “equivalent” to the one prescribed is primarily for the employer or the expert body to decide and that the Court, in exercise of judicial review, does not ordinarily sit in appeal over such academic or policy determinations. (Para 33) Even where the State acts in its contractual capacity, it does not shed its constitutional character and remains bound by the obligations of fairness, non-arbitrariness and reasonableness under Article 14. (Para 41) where a contractual employee is terminated on the sole ground of ineligibility, the Court is entitled to examine whether that ground is factually correct and whether relevant material was properly considered. (Para 42)
Case Info
Case Details
- Case name: LAXMIKANT SHARMA v. State of Madhya Pradesh & Ors.
- Neutral citation: 2025 INSC 1385
- Coram: Sanjay Karol, J.; Vipul M. Pancholi, J.
- Judgment date: December 04, 2025
- Appeal/SLP reference: SLP (C) No. 18907 of 2025; Civil Appeal (arising out of SLP (C) No. 18907 of 2025)
- Court: Supreme Court of India, Civil Appellate Jurisdiction
- Disposition: Appeal allowed; High Court judgments set aside; reinstatement directed within four weeks with consequential benefits; non‑precedential clarification.
Caselaws and Citations
- Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad: (2019) 2 SCC 404
- Unnikrishnan C.V. v. Union of India: 2023 SCC OnLine SC 343
- Shifana P.S. v. State of Kerala: (2024) 8 SCC 309
- State of Uttar Pradesh v. Raj Kumar Sharma: (2006) 3 SCC 330
- Arup Das v. State of Assam: (2012) 5 SCC 559
- Tinku v. State of Haryana: 2024 SCC OnLine SC 3292
- GRIDCO Ltd. v. Sadananda Doloi: (2011) 15 SCC 16
Statutes / Laws Referred
- Article 14 of the Constitution of India (fairness, non‑arbitrariness, equal protection)
- Principles of natural justice (right to be heard)
- Service jurisprudence on strict compliance with prescribed qualifications and limits of judicial review in academic/equivalence matters.
