In a significant ruling that may quietly ripple through recruitment practices in government departments, the Supreme Court on Thursday set aside the Madhya Pradesh High Court’s decision that had upheld the termination of Monitoring and Evaluation Consultant Laxmikant Sharma. The bench found that the State had relied on “incorrect assumptions” and ignored crucial academic records before dismissing him.
Background
Sharma, who had been appointed in 2013 under the State Water Mission’s Monitoring and Evaluation wing, was removed after an eight-member committee concluded that he lacked the prescribed qualification: a postgraduate degree in Statistics. Sharma’s M.Com. included Business Statistics and Indian Economic Statistics as principal subjects. He insisted this fulfilled the advertisement requirement, especially because no university in Madhya Pradesh even offered a PG degree titled “M.Com (Statistics)”.
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Yet the committee held that “none of the subjects mentioned in the mark sheet” related to Statistics - a finding later contradicted by the college’s own certification. Despite multiple High Court remand orders over the years, the State again reaffirmed termination in 2018 and 2020, prompting Sharma to approach the Supreme Court.
Court’s Observations
The bench noted that the heart of the dispute lay not in “equivalence” of degrees but in interpreting what a “postgraduate degree in Statistics” reasonably meant in context.
“The bench observed, ‘Insisting solely on the title of the degree, without considering the curriculum, elevates form over substance’,” referring to how the State mechanically rejected the qualification without examining the actual subjects studied.
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The Court also emphasised two critical lapses:
- The committee’s factual error: It wrongly claimed Sharma had no Statistics-related subjects, despite the later university certificate explicitly confirming he had passed M.Com. in Business Statistics.
- Violation of natural justice: The appellant was never given a chance to present his documents before the inquiry committee.
Terming these omissions as “arbitrary and uninformed”, the Court held that subsequent termination orders continued relying on the flawed 2013 report while ignoring crucial documents - including a detailed 2019 opinion from the Director of the Water Mission. That opinion stated Sharma did fulfil the advertised qualification and had performed satisfactorily.
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The bench observed, “Once the competent domain authority has examined the curriculum and certified eligibility, the State gave no reason to disregard that expert view.”
The Court was also unconvinced by the State’s argument of “negative equality”. Sharma was not asking for parity with ineligible candidates, the bench clarified, but claiming he was actually eligible, just like others who remained in service with similar qualifications.
In a reminder to governments dealing with contractual staff, the Court said even contractual decisions must meet constitutional standards of fairness: “The State does not shed its constitutional character when acting in contractual capacity.”
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Decision
Holding the termination arbitrary and unreasonable, the Supreme Court set aside the High Court judgments and ordered Sharma’s reinstatement within four weeks, along with all consequential benefits. The bench clarified that the ruling was based on the unique facts of this case and should not be treated as a general precedent.
Case Title: Laxmikant Sharma vs. State of Madhya Pradesh & Others
Case No.: Civil Appeal (Arising out of SLP (C) No. 18907 of 2025)
Case Type: Civil Appeal – Service Matter (Termination of Contractual Employment)
Decision Date: 04 December 2025
