Himanshu Kumar Singh v. Indian Oil Corporation Limited & ANR.

$~84 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 5495/2026 HIMANSHU KUMAR SINGH .....Petitioner Through:

Mr. Anubhav Singh, Mr. Ayush Gangwar and Mr. Rahul Kumar Sharma, Advocates.

versus INDIAN OIL CORPORATION LIMITED & ANR. .....Respondents Through:

Mrs. Anubha Bhardwaj, CGSC with Ms. Ananya Shamshery, Advocate for R-2.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 23.04.2026 1.

The Petitioner assails the communications dated 10th December, 2025 and 5th January, 2026, whereby his candidature for the post of Engineer/Officer, Grade-A, in Indian Oil Corporation Limited was rejected on the ground that his qualifying degree, namely B.Tech "Chemical-Plastics and Polymer", does not fall within the eligible engineering disciplines prescribed in the recruitment advertisement.

2.

The petition has been heard at the admission stage. Since the controversy turns on the Petitioner's own documents, the terms of the advertisement, and the admitted nomenclature of the degree, this Court does not consider it necessary to issue notice at this stage before examining whether any case for interference is made out. W.P.(C) 5495/2026 Page 1 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

3.

Indian Oil Corporation Limited1 issued Advertisement No. IOCL/COHR/RECTT/2025/01 dated 5th September, 2025 for recruitment to the post of Engineers/Officers (Grade-A) through Computer Based Test, 2025. The recruitment was notified for three disciplines, namely Chemical, Electrical and Instrumentation.

4.

The Petitioner holds a Bachelor of Technology degree from Birla Institute of Technology,2 Mesra. The degree certificate describes the qualification as Bachelor of Technology in "Chemical-Plastics and Polymer". The Petitioner completed the course in May, 2022, securing First Class with Distinction. He submitted his online application on 8th September, 2025. In the application form, the discipline was indicated as "Chemical", the degree as B.Tech, and the subject/stream as "Chemical". The Petitioner appeared in the Computer Based Test on 31st October, 2025 and secured 68.75 marks. Having crossed the qualifying cut-off for the General category, he was shortlisted for the next stage comprising Group Discussion, Group Task and Personal Interview. 5.

The call letter dated 14th November, 2025 scheduled the Petitioner's GD, GT and PI on 24th November, 2025 at the Indian Oil Management Centre of Learning, Mumbai. The call letter, however, was not an unconditional acceptance of eligibility. It specifically stated that the Petitioner was provisionally shortlisted and that he would be permitted to participate only if he met the eligibility criteria prescribed in the advertisement and produced valid and relevant original documents in support of the information furnished in the application form. 1 "IOCL"

2 "BIT"

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6.

The Petitioner participated in the selection process. His grievance is that once he was permitted to participate in the GD, GT and PI, the Respondent could not thereafter reject his candidature on the ground of degree nomenclature. The impugned communication dated 10th December, 2025 records that while the Petitioner had indicated his qualifying degree branch as Chemical Engineering in the application form, the degree produced by him reflected the branch as "Chemical-Plastics and Polymer", which was not specified as an eligible qualification in the detailed advertisement. The subsequent communication dated 5th January, 2026 reiterates this position, with reference to Clause 1.0 and Clause 7.11(b) of the detailed advertisement.

7.

Mr. Anubhav Singh, counsel for the Petitioner, submits that the rejection is arbitrary, hyper-technical and contrary to the substance of the Petitioner's qualification. The Petitioner does not dispute that his degree certificate bears the title B.Tech "Chemical-Plastics and Polymer". His case is that the title does not capture the true nature of the course. The degree is a regular four-year Chemical Engineering degree with a specialization in plastics and polymer, mostly in the final two semesters. 8.

Considerable reliance is placed on a clarification dated 17th November, 2025 issued by the Head of Department, Chemical Engineering, BIT, Mesra. The certificate states that the Petitioner studied B.Tech "Chemical-Plastics and Polymer" in the Department of Chemical Engineering, BIT Mesra during the academic years 2018-2022, and that the said course is a regular four-year B.Tech degree comprising all Chemical Engineering core subjects with specialization subjects related to polymers mostly in the last two semesters.

W.P.(C) 5495/2026 Page 3 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

9.

Mr. Singh further submits that the Petitioner has studied the core subjects of Chemical Engineering. A comparison table of the curricula for B.Tech (Chemical Engineering) and B.Tech (Chemical-Plastics and Polymer) at BIT Mesra has been placed on record, which demonstrates substantial overlap in foundational subjects and establishes equivalence in academic content.

10.

It is further urged that the Petitioner cleared the CBT, participated in all later stages of the process and, on the basis of the marks disclosed under the Right to Information Act, secured a composite score above the final General category cut-off. The Petitioner, therefore, is not merely eligible but meritorious, and that his rejection defeats the object of selecting the best Chemical Engineering candidate.

11.

Mr. Singh also points out that other Public Sector Undertakings and Government-linked bodies have treated the Petitioner's degree as sufficient for Chemical Engineering posts. Engineers India Limited is stated to have shortlisted the Petitioner for an interview for the post of Engineer (Chemical). It is also stated that the Petitioner was selected by HPCL Rajasthan Refinery Limited. These instances, show that IOCL has adopted an unduly rigid and isolated view of the same qualification. 12.

The Petitioner also invokes the doctrines of legitimate expectation and estoppel. It is submitted that once IOCL verified his documents on 24th November, 2025 and allowed him to participate in GD, GT and PI, it was not open to IOCL to turn around and reject the same degree after the Petitioner had invested time, money and effort in the selection process. 13.

Reliance is lastly placed on Laxmikant Sharma v. State of Madhya W.P.(C) 5495/2026 Page 4 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

Pradesh.3 Therein, the Supreme Court rejected an approach which treats nomenclature as conclusive and held that substance must prevail over form where the curriculum shows that the candidate has studied the required subjects. Therefore, IOCL ought to have looked at the Petitioner's curriculum and not merely the words appearing on the degree certificate. 14.

This Court has considered the submissions and perused the record. The determination must turn, in the first instance, on the terms of the advertisement. Clause 1.0 prescribes the essential educational qualifications, including the requirement of a B.Tech/BE or equivalent degree, obtained through a full-time regular course from a recognised institution, in the specified disciplines. The relevant extract of the advertisement reads as follows:

3 2025 SCC OnLine 2712.

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15.

The same table also set out eligible disciplines for Electrical Engineering and Instrumentation Engineering. Notably, for both streams, the advertisement enumerated a wide range of variants and allied branches. 16.

This structure of the advertisement indicates that IOCL did not use vague or open-ended language. It did not say that all degrees containing core Chemical Engineering subjects would be accepted. Nor did it say that any degree granted by the Department of Chemical Engineering would suffice. It specified the eligible disciplines and, significantly, did so by reference to the discipline "as mentioned on Degree Certificate". 17.

The advertisement also contains a note that candidates having a qualifying degree from a discipline other than those listed would not be eligible to apply. The note further states that IOCL reserved the right to take a final decision in considering an engineering discipline eligible if it differed from those mentioned above. This reservation of power is enabling in nature. It does not confer an enforceable right upon every candidate with an adjacent or allied qualification to demand inclusion. It merely preserves the employer's discretion in marginal cases. Unless that discretion is shown to have been exercised perversely, mala fide, or in a manner contrary to the advertisement itself, the Court cannot substitute its own view. 18.

The degree certificate produced by the Petitioner does not mention any of the disciplines listed in the Chemical Engineering column of the advertisement. It mentions B.Tech "Chemical-Plastics and Polymer". That is the difficulty which the Petitioner has not been able to overcome. The Petitioner's argument is not that his degree title is one of the prescribed titles. The argument is that, despite the title, the curriculum is substantially the same as Chemical Engineering and should, therefore, be treated as W.P.(C) 5495/2026 Page 6 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

equivalent or sufficient.

19.

That submission, however attractive at first blush, invites the Court into an area where judicial review must move with restraint. Whether a particular degree, by reason of its curriculum, practical training, departmental affiliation or subject overlap, should be treated as equivalent to a prescribed qualification is not ordinarily for the writ court to decide. It is a matter for the employer, the rule-making authority, or an expert academic body.

20.

The Supreme Court in Maharashtra Public Service Commission v. Sandeep Shriram Warade,4 held that essential qualifications for appointment are for the employer to decide. The Court cannot lay down eligibility conditions, nor can it rewrite an advertisement by treating desirable or allied qualifications as equivalent to the prescribed one. It was also held that questions of equivalence fall outside the ordinary domain of judicial review where the advertisement and rules are clear. 21.

The same principle was stated in Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad.5 The Supreme Court held that judicial review can neither expand the ambit of prescribed qualifications nor decide equivalence between a prescribed qualification and another qualification. The Court cannot read into the recruitment conditions what the employer has consciously chosen not to include.

22.

More recently, in Shifana P.S. v. State of Kerala,6 the Supreme Court reiterated that equivalence is a technical academic matter. It cannot be implied or assumed. A claim of equivalence must rest on a specific decision 4 (2019) 6 SCC 362.

5 (2019) 2 SCC 404.

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or resolution of the competent academic or statutory authority and cannot be created by judicial comparison of syllabi.

23.

These principles apply with particular force to public recruitment. The terms of an advertisement are not private correspondence between the employer and one candidate. They are a public representation to all potential applicants. If a Court expands the listed qualifications after the selection process has begun, it risks disturbing the level field. There may be other candidates holding similarly named degrees who did not apply because the advertisement did not include their discipline. Fairness in recruitment is owed not only to the candidate before the Court, but also to those absent candidates who arranged their affairs according to the published conditions. 24.

The Petitioner's curriculum comparison does show that he studied several core Chemical Engineering subjects. The certificate of BIT Mesra also supports the Petitioner to the extent that his course was a regular fouryear B.Tech course and comprised Chemical Engineering core subjects along with specialization subjects related to polymers. This Court does not doubt the academic worth of the Petitioner's degree. Nor does it doubt that the Petitioner may be technically competent in many areas of Chemical Engineering.

25.

But the legal test is not whether the Petitioner is a good engineer. The issue is whether the Court can compel IOCL to treat B.Tech "ChemicalPlastics and Polymer" as falling within the list of eligible disciplines published in the advertisement. On the present record, it cannot. The BIT Mesra clarification cannot carry the matter further. It certifies the content and structure of the Petitioner's course. It does not certify that the 6 (2024) 8 SCC 309.

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Petitioner's degree is the same as B.Tech Chemical for all recruitment purposes. It does not state that the Academic Council or any competent statutory body of BIT Mesra has declared B.Tech "Chemical-Plastics and Polymer" equivalent to any of the listed IOCL disciplines. Above all, it cannot bind IOCL in the matter of eligibility for a post in its own establishment.

26.

The Petitioner's reliance on Laxmikant Sharma does not alter the position. That case turned on its own facts. There, the qualification was phrased as "Postgraduate degree in Statistics". The candidate held an M.Com. degree in which Business Statistics and Indian Economic Statistics were principal subjects. The Supreme Court noticed that no Government university in Madhya Pradesh offered a postgraduate course titled "M.Com. (Statistics)" or a standalone postgraduate degree exclusively bearing "Statistics" in its nomenclature. There was also a considered departmental expert opinion, after scrutiny of the marksheets and curriculum, that the candidate satisfied the advertised requirement. The Supreme Court further clarified that the decision was rendered in the peculiar facts of that case and would not operate as a precedent for treating differently named qualifications as equivalent in other cases.

27.

The present case is different. IOCL did not prescribe a broad, generic qualification such as "degree in Chemical Engineering" without more. It provided a table of eligible disciplines and tied eligibility to the discipline as mentioned on the degree certificate. It included several variants in Electrical and Instrumentation, and within the Chemical column it included Petrochemical and Refinery-linked degrees. The omission of "ChemicalPlastics and Polymer", "Polymer Technology", "Plastic Technology" or any W.P.(C) 5495/2026 Page 9 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

similar formulation cannot be supplied by the Court. 28.

The Petitioner's case is, therefore, closer to the line of authorities where courts have declined to treat an allied or overlapping qualification as equivalent to the one expressly prescribed. Subject overlap is not identity. A curriculum may share many courses with another curriculum and still remain a distinct degree for recruitment purposes. That is particularly so where the advertisement itself proceeds by specified nomenclature. 29.

There is another aspect. The Petitioner's application form shows that he described his subject/stream as "Chemical". The degree certificate, when produced, showed the degree title as "Chemical-Plastics and Polymer". The impugned communication proceeds on precisely this difference. The Court is not treating this as a case of misrepresentation. It is possible that the Petitioner bona fide believed that his specialization fell within Chemical Engineering. But IOCL was entitled, at the stage of document verification, to compare the application entries with the degree certificate and decide whether the degree produced satisfied Clause 1.0. 30.

Nor does provisional shortlisting create a right in favour of the Petitioner. The CBT result itself stated that shortlisting was provisional and subject to production of valid and relevant documents at the time of document verification. The call letter carried the same caveat. Clause 6.4 of the advertisement stated that eligibility of shortlisted candidates would be verified before GD, GT and PI, and that candidature and selection would remain provisional and subject to subsequent verification of certificates, testimonials, medical fitness and other requirements. The Petitioner's own application declaration also recorded that if the information furnished was found not to satisfy the eligibility criteria, IOCL would be at liberty to W.P.(C) 5495/2026 Page 10 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

cancel the candidature, appointment or selection. 31.

In these circumstances, participation in GD, GT and PI cannot cure an eligibility defect. It is settled that selection procedure and eligibility operate at different stages. A candidate may perform well in the examination and interview, yet remain disentitled if he does not possess the prescribed qualification. Merit cannot override eligibility. Sympathy cannot rewrite the advertisement.

32.

The argument based on legitimate expectation and estoppel also fails for the same reason. A legitimate expectation must rest on a clear and unambiguous representation. Here, every material document told the Petitioner that his candidature was provisional and that eligibility remained subject to verification. Allowing him to participate in later stages, whether on account of initial scrutiny, administrative sequencing, or pending verification, cannot amount to a promise that IOCL had accepted his degree as eligible. In Sandeep Shriram Warade, the Supreme Court dealt with a similar situation where candidates were permitted to participate in the selection process after a Scrutiny Committee had examined their documents.

It was determined that the constitution of an expert committee and the subsequent invitation to interview cannot operate as an estoppel against the clear terms of the advertisement to render an ineligible candidate eligible. Participation in the selection process does not override the essential eligibility criteria, and there can be no estoppel against an express eligibility condition in a public recruitment process.

33.

The fact that other PSUs or Government-linked employers may have shortlisted or selected the Petitioner also does not bind IOCL. Recruitment conditions vary from employer to employer. A degree may be accepted by W.P.(C) 5495/2026 Page 11 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

one organisation for one post and yet not fall within another organisation's advertised eligibility criteria. Article 14 does not require every public employer to treat all allied technical qualifications alike regardless of the terms of its own recruitment notice.

34.

The Petitioner's contention that there is no intelligible differentia between Chemical Engineering and Chemical-Plastics and Polymer is, in essence, a plea for treating the two as equivalent. That issue, however, lies outside the scope of judicial review in light of the settled principles noted above.

35.

The note in the advertisement preserving IOCL's right to consider a different engineering discipline eligible also does not assist the Petitioner. The discretion remained with IOCL. The Court may examine whether a discretion has been exercised arbitrarily, but it cannot compel the employer to exercise that discretion in favour of one candidate merely because the Court considers the course content comparable. On the material placed by the Petitioner, IOCL's view is a plain reading of the advertisement and the degree certificate. It may appear strict. It cannot be said to be perverse. 36.

The Petitioner has urged that he has secured marks above the General category cut-off. Even if that contention is accepted for the present purpose, it does not affect the result. The merit list is to be prepared only of candidates who qualify in all components of the selection process and satisfy the prescribed eligibility criteria. A candidate who is ineligible does not enter the zone of comparative merit. The cut-off applies after eligibility, not before it.

37.

The Court is conscious that the Petitioner is a young engineer, that he has performed well in the recruitment process, and that exclusion at a late W.P.(C) 5495/2026 Page 12 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

stage may be disheartening. But a public recruitment process cannot be decided on personal hardship. The rule must be applied as published. To do otherwise would be unfair to the recruiting body and to all candidates who either applied, or chose not to apply, on the basis of the advertised disciplines.

38.

For the reasons aforesaid, this Court finds no illegality, arbitrariness or perversity in the decision of IOCL to reject the Petitioner's candidature on the ground that B.Tech "Chemical-Plastics and Polymer" is not one of the eligible engineering disciplines prescribed in the advertisement. 39.

The writ petition is accordingly dismissed. Pending applications, if any, also stand disposed of.

SANJEEV NARULA, J APRIL 23, 2026 as W.P.(C) 5495/2026 Page 13 of 13 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.