CHANDRA SHEKHAR SINGH AND OTHERS versus THE STATE OF JHARKHAND AND OTHERS

Citation: [2025] 4 S.C.R. 129 · Decided: 19-03-2025 · Supreme Court of India · Bench: VIKRAM NATH · Disposal: Appeal(s) allowed

cites 1 · see the full citation network in Lexace

Judgment (excerpt)

[2025] 4 S.C.R. 129 : 2025 INSC 372
Chandra Shekhar Singh and Others 
v. 
The State of Jharkhand and Others
(Civil Appeal No. 10389 of 2024)
20 March 2025
[Vikram Nath and Sandeep Mehta,* JJ.]
Issue for Consideration
Whether the term ‘degree’ as mentioned in the rules and the 
recruitment notification for the appointment as Food Safety Officer 
(FSO) issued by the Jharkhand Public Service Commission can 
be restricted to “Bachelor’s degree” or whether the same would 
cover in its ambit, the “Master’s degree” as well.
Headnotes†
Food Safety and Standard Act, 2006 – ss.37, 91 – Food Safety 
and Standard Rules, 2011 – 2022 Amendment – University 
Grants Commission Act, 1956 – s.22(3) – Disqualification for 
possessing higher degree in the subject prescribed under 
the advertisement, not proper – Selection for the post of 
FSO  – Appellants were disqualified from the recruitment 
process on the ground that the degrees of post-graduation 
held by them in relevant subject(s) did not meet the 
qualification criteria in terms of the subject advertisement 
which provided that the required degree should be at the 
graduate level only – Disqualification upheld by High Court – 
Interference with:
Held: Appellants possessing post-graduate degrees in subjects 
covered under Clause 2.1.3 of the FSS 2011 Rules are qualified 
for the post of FSO under the subject advertisement – Under 
s.22(3), UGC Act, ‘degree’ means the ‘Bachelor’s Degree’, 
‘Master’s Degree’ and the ‘Doctorate Degree’ – Thus, wherever 
the word ‘degree’ is used, unless a specific exclusion is provided, 
the same would include all three, ‘Bachelor’s Degree’, ‘Master’s 
Degree’ and a ‘Doctorate Degree’ – There is no ambiguity 
* Author
130
[2025] 4 S.C.R.
Supreme Court Reports
whatsoever in the FSS 2011 Rules or the subject advertisement 
which can exclude the Master’s degree in subjects referred to 
in the preceding part of the Rule 2.1.3 of the FSS 2011 Rules, 
other than Chemistry, as being a valid qualification – The special 
reference to the Master’s degree is given in the said Rule, only 
for those who have acquired their degree course in Chemistry 
subject, for whom, the minimum qualifying criterion will be a 
Master’s degree in Chemistry – However, so far as the other 
subjects are concerned, a person having any degree, be it 
graduation or post-graduation, would be equally qualified for the 
post in question – Impugned judgments set aside – Golden Rule 
of Interpretation. [Paras 29, 31, 32, 34, 35]
Food Safety and Standard Act, 2006 – ss.37, 91, 94 – 
Powers exercised by the Central Government vis-à-vis State 
Government – Scope – Discussed – Food Safety and Standard 
Rules, 2011. [Paras 24-26]
Case Law Cited
Parvaiz Ahmad Parry v. State of Jammu and Kashmir and Others 
[2015] 12 SCR 810 : (2015) 17 SCC 709 – relied on.
List of Acts
University Grants Commission Act, 1956; Food Safety and Standard 
Act, 2006; Food Safety and Standard Rules, 2011.
List of Keywords
Food Safety Officer; Jharkhand Public Service Commission; 
Post of FSO in the State of Jharkhand; Recruitment process; 
Disqualification; Higher degree; Disqualified during course 
of recruitment; Educational qualification; Master’s degree 
valid qualification; “degree”; ‘Bachelor’s Degree’; ‘Master’s  
Degree’; ‘Doctorate Degree’; Golden rule of interpretation; Literal 
sense.
Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No. 10389 of 2024
From the Judgment and Order dated 02.08.2023 of the High Court 
of Jharkhand at Ranchi in LPA No. 244 of 2020
[2025] 4 S.C.R. 
131
Chandra Shekhar Singh and Others v.  
The State of Jharkhand and Others
Appearances for Parties
Advs. for the Appellants:
Anup Kumar, Vishnu Prabhakar Pathak, Ms. Shruti Singh,  
Ms. Pragya Chaudhary, Awanish Gupta, Mrs. Neha Jaiswal, 
Shivam Kumar.
Advs. for the Respondents:
Jayant Mohan, Ms. Meenakshi Chatterjee, Ms. Adya Shree Dutta, 
Himanshu Shekhar, Parth Shekhar, Shubham Singh, Mrs. Revathy 
Raghavan, Ms. Kavya Roy Choudhury, Rohit Gupta.
Judgment / Order of the Supreme Court
Judgment
Mehta, J.
1.	
Heard.
2.	
The appellants have approached this Court by way of this appeal 
seeking a direction upon the respondents to consider the candidature 
of the appellants for appointment as Food Safety Officers1, pursuant 
to the notification dated 7th October, 2015 issued by the Jharkhand 
Public Service Commission2 upon the requisition of the State of 
Jharkhand.
3.	
The appellants herein have the qualifications of post-g

Excerpt shown. Read the full judgment & AI analysis in Lexace.