Dismissed¶100

K.Vijayakumar, v. The Secretary

Madras HC15 Jul 2026WP/24215/2018

Case brief

AI extract

What is this about?

Forest Apprentice recruitment; TNPSC Notification No.12/2018 (04.07.2018) and No.20/2022 (08.08.2022); G.O.(Ms).No.143 Environment and Forest Department dated 22.11.2017; G.O.(Ms) No.42 dated 29.02.2016; equivalence of M.Sc. Wildlife Biology (Bharathidasan University) with B.Sc. Forestry; 47th Equivalence Committee meeting 04.03.2014; judicial review cannot substitute expert/Government view on degree equivalence; concluded selection process; Special Rules for Tamil Nadu Forest Subordinate Service amended; Article 226 certiorarified mandamus; writ petitions dismissed, no costs; Neutral Citation 2026:MHC:3007.

What did the court decide?

None; writ petitions dismissed with no costs and connected miscellaneous petitions, if any, closed. ¶100

K.Vijayakumar, Vs The Secretary — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

None; writ petitions dismissed with no costs and connected miscellaneous petitions, if any, closed.

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Issue for consideration

Whether M.Sc. Wildlife Biology awarded by the Bharathidasan University is equivalent to B.Sc. Forestry for recruitment to the post of Forest Apprentice. +1 more

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Court's answer

Equivalence between two degrees granted by Universities is determined based on domain experts; when the expert committee's opinion has been accepted by the Government, the High Court in exercise of its powers of judicial review cannot substitute its own views regarding the equivalence between the two degrees.

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Ratio / Principle

Since the 2018 recruitment notification's selection process had concluded long before, with selected candidates appointed and working for several years, the writ petitioners are not entitled to any further relief from the Court.

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Key takeaways

The relief sought to assail the Government's amendment to the Special Rules for Tamil Nadu Forest Subordinate Service deserves no merit consideration, this Court having already considered the issue of equivalence between M.Sc. Wildlife Biology and B.Sc. Forestry.ratio¶99

Detailed headnote1 paragraphs

Madras High Court (S.M. Subramaniam J. and N. Senthilkumar J.; order by S.M. Subramaniam J.), Neutral Citation 2026:MHC:3007, dated 15-07-2026 — Writ petitions under Article 226 by holders of M.Sc. Wildlife Biology (Bharathidasan University) seeking quashing of G.O.(Ms).No.143 dated 22.11.2017, G.O.(Ms) No.42 dated 29.02.2016 and TNPSC Notifications No.12/2018 and No.20/2022, and inclusion of M.Sc. Wildlife Biology as a preferred/equivalent degree to B.Sc. Forestry for Forest Apprentice recruitment. Held: (i) grant of equivalence between university degrees rests with domain experts, and once the Equivalence Committee's (47th meeting, 04.03.2014) finding of non-equivalence was accepted by the Government, the High Court in judicial review cannot substitute its own view; (ii) the 2018 selection process had concluded and selected candidates were appointed and working, so no further relief was due; (iii) relief against the Government's amendment to the Special Rules for Tamil Nadu Forest Subordinate Service (essential qualification: Bachelor's degree in Forestry or equivalent) deserved no merit consideration. All writ petitions dismissed; no costs.

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2026:MHC:3007

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WP No. 24215 of 2018

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 15-07-2026

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CORAM

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THE HON'BLE MR JUSTICE S. M. SUBRAMANIAM

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AND

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THE HON'BLE MR.JUSTICE N.SENTHILKUMAR

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WP No. 24215 of 2018, WP NO. 23829 OF 2018 and WP NO. 31008 OF 2022

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WP No. 24215 of 2018

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K.Vijayakumar,

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K.Narasimmarajan

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B.Navaneethan

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J.Yogesh

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P.Francis

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..Petitioner(s)

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The Secretary Tamil Nadu Public Service Commission, TNPSC Road, V.O.C. Nagar, Park Town, Chennai – 600003

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The Secretary Department of Environment & Forest, Government of Tamil Nadu, Fort St. George, Chennai - 600009

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..Respondent(s)

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WP No. 23829 of 2018

K.Srinivasan

..Petitioner(s)

The Secretary Tamil Nadu Public Service Commission, TNPSC Road, V.O.C.Nagar, Park Town,

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__________ Page1 of 9

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https://www.mhc.tn.gov.in/judis

2026:MHC:3007

WP No. 24215 of 2018

Chennai - 600003

The Secretary Department of Environment & forest, Namakkal Kavignar maaligai, Governmentt of Tamil Nadu, Fort St. George, Chennai -9

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..Respondent(s)

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WP No. 31008 of 2022

K.Srinivasan

..Petitioner(s)

The Secretary Tamil Nadu Public Service Commission, TNPSC Road, VOC Nagar, Part Town, Chennai-03, Tamil Nadu, India.

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the Secretary

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Department of Environment and Forest, Namakkal Kavignar Maaligai, Govt of Tamil Nadu, Fort St. George, Chennai-09, Tamil Nadu, India.

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..Respondent(s)

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WP No. 24215 of 2018

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Writ Petition filed under under Article 226 of the Constitution of India issuing writ of certiorarified mandamus calling for the records related to G.O. (Ms). No.143, dated 22.11.2017 issued by Environment and Forest Department of Tamil Nadu Government consequential Notification No.12/2018 dated 04.07.2018 issued by Tamil Nadu Public Service Commission, and to quash the same as illegal, and directing the 1^st respondent to re-issue a fresh Notification including M.Sc., Wildlife Biology degree as a preferred degree or equivalent degree to B.Sc., Forestry in the recruitment for the post of “Forest Apprentice”.

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WP No. 23829 of 2018

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Writ Petition filed under under Article 226 of the Constitution of India issuing writ of certiorarified mandamus calling for the records related to G.O. (Ms). No. 143 dated 22.11.2017 issued by Environment and Forest

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Page2 of 9

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https://www.mhc.tn.gov.in/judis

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2026:MHC:3007

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WP No. 24215 of 2018

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Department of Tamil Nadu Government and Consequential Notification No. 12/ 2018 dated 04.07.2018 issued by Tamil Nadu Public Service Commission, and to quash the same as illegal, and directing the 1st respondent to re-issue a fresh Notification including M.Sc., Wildlife Biology degree as a preferred degree or equivalent degree to B.Sc., Forestry in the recruitment for the post of “Forest Apprentice”.

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WP No. 31008 of 2022

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Writ Petition filed under under Article 226 of the Constitution of India issuing writ of certiorarified mandamus calling for the records related to G.O. (Ms) No.42, dated 29.02.2016 issued by Environment and Forests (FR-2) Department, and Notification No.20/2022 dated 08.08.2022 issued by Tamil Nadu Public Service Commission without including the degree of M.Sc., Wildlife Biology as a preferred or equivalent qualification to B.Sc., Forestry and to quash both the said G.O and the said Notification as illegal, and directing the 1st respondent to include M.Sc., Wildlife Biology degree as a preferred degree or equivalent degree to B.Sc., Forestry in the recruitment for the post of Forest Apprentice.

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WP No. 24215 of 2018

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For Petitioner(s): Mr.G.Saravanan For Respondent(s): Mr.K.Karthik Jagannath, Standing Counsel for TNPSC for R1, Dr.R.Gouri, Government Counsel for R2

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WP No. 23829 of 2018

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For Petitioner(s): Mr.G.Saravanan For Respondent(s): Mr.K.Karthik Jagannath, Standing Counsel for TNPSC for R1, Dr.R.Gouri, Government Counsel for R2

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WP No. 31008 of 2022

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For Petitioner(s): Mr.K.Venkatramani Senior Counsel for Mr.M.Vignesh Raj

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https://www.mhc.tn.gov.in/judis

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2026:MHC:3007

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WP No. 24215 of 2018

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For Respondent(s): Mr.K.Karthik Jagannath, Standing Counsel for TNPSC for R1, Dr.R.Gouri, Government Counsel for R2

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Common Order

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(Order of the Court was made by S.M.Subramaniam J.)

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The reliefs sought for in the present writ petitions are to quash G.O. (Ms). No. 143, Environment and Forest Department, dated 22.11.2017 as well as recruitment notification No.12/2018, dated 04.07.2018 issued by the Tamil Nadu Public Service Commission, and direct the 1^st respondent to re-issue a fresh notification including M.Sc. Wildlife Biology degree as preferred degree

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or equivalent degree to B.Sc. Forestry for recruitment to the post of Forest Apprentice.

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The writ petitioners have completed M.Sc Wildlife Biology. The issue involved is whether M.Sc. In Wildlife Biology awarded by the Bharathidasan University is equivalent to the B.Sc in Forestry. As per recruitment notification

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of the year 2017, qualification fixed for the post of forest apprentice is

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Name of the post	Educational Qualification Preferential Qualification
Forest Apprentice	(a) Must possess a Bachelor's degree in Forestry or its equivalent degree of any Institution or University recognized by UGC Only if suitable candidates with the educational qualification referred to in item (a) in column (2) are not available for selection, candidates with qualification referred to in

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https://www.mhc.tn.gov.in/judis

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2026:MHC:3007

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WP No. 24215 of 2018

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OR	item (b) will be
	considered for selection
(b) Must possess a Bachelor's Degree or its equivalent degree in any one of the following subjects from any Institution or University recognized by UGC	process in the respective communal categories.
1. Agriculture
2. Animal Husbandry and Veterinary Science
3. Botany
4. Chemistry
5. Computer Applications/ Computer Science
6. Engineering (All Engineering subjects including Agricultural Engineering)
7. Environmental Science
8. Geology
9. Horticulture
10. Marine Biology
11. Mathematics
12. Physics
13. Statistics
14. Wildlife biology
15. Zoology

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https://www.mhc.tn.gov.in/judis

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2026:MHC:3007

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WP No. 24215 of 2018

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The petitioners admittedly possess the educational qualification of M.Sc. Wildlife Biology, which is not considered as qualification for recruitment to the post of Forest Apprentice. Representations were submitted, and issue was placed before the Equivalence Committee. Equivalence committee in its 47^th meeting held on 04.03.2014 submitted its recommendations. Government accepted the resolution/recommendation of the 47^th Equivalence Committee held on 04.03.2014 and issued G.O.(Ms).No.143, Environment and Forest Department, dated 22.11.2017 that the qualification of M.Sc. Wildlife Biology awarded by the Bharathidasan University is not equivalent to B.Sc. in Forestry. Thus, the writ petitioners are ineligible to participate in the process of selection in respect of the recruitment notification issued.

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Learned counsel for the petitioners would submit that M.Sc. Wildlife

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Biology is also a subject dealing with conflict between man and animal, and conservation of forest. Therefore, it is to be treated as equivalent to B.Sc in Forestry. M.Sc. in Wildlife Biology has been a preferential qualification for the last around three decades for the post of Forest Apprentice and Assistant Conservator of Forest as per the Government orders. Therefore, Government order issued in G.O.(Ms). No. 143, Environment and Forest Department, dated 22.11.2017 is to be set aside.

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https://www.mhc.tn.gov.in/judis

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2026:MHC:3007

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WP No. 24215 of 2018

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This Court is of the considered view that grant of equivalence

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between two degrees granted by Universities are issued based on domain experts. The opinion of the academic experts have been obtained and equivalence committee in the present has recommended that the degree of M.Sc Wildlife Biology is not equivalent to B.Sc. in Forestry. When the opinion of the experts committee has been accepted by the Government, High Court, in exercise of its powers of judicial review cannot substitute its views regarding

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the equivalence between the two degrees granted by the Universities.

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That apart, recruitment notification was issued in the year 2018 and

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process of selection concluded long before. Selected candidates were appointed and working for the past several years.

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Under these circumstances, the writ petitioners are not entitled for any further relief from the hands of this Court.

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Further, Government has amended the Special rules for Tamil Nadu Forest Subordinate Service. Accordingly, the essential qualification for recruitment to the post of Forest Apprentice is “must possess a Bachelor's degree in Forestry or its equivalent degree of any Institution or University recognized by UGC”

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https://www.mhc.tn.gov.in/judis

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2026:MHC:3007

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WP No. 24215 of 2018

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This Court has already considered the issue regarding grant of

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equivalence between M.Sc Wildlife Biology and B.Sc in Forestry. In view of the said factum, relief sought for to assail the amendment made by the Government to the Special Rules for Tamil Nadu Forest Subordinate Service deserves no merit consideration.

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