Court defers to expert academic and government policy decisions, dismisses petitions challenging exclusion of Biotechnology from allied subjects list under UGC regulations
In a significant judgment delivered on October 6, 2026, the Allahabad High Court upheld the decision of the Uttar Pradesh State Government and the Uttar Pradesh Education Service Selection Commission to exclude Biotechnology from the list of allied or relevant subjects to Zoology for the recruitment of Assistant Professors. The petitioners, including Dr. Vartika Mishra and others, challenged the recruitment advertisement dated September 8, 2026, which omitted Biotechnology as an allied subject for Zoology, arguing that Biotechnology is an interdisciplinary branch closely connected with Zoology and should be recognized as such.
The court observed that the identification of allied or relevant subjects is an academic and policy determination resting with expert bodies and the competent government authority. The State Government had constituted an Expert Committee that recommended the subjects eligible to be treated as allied or relevant to Zoology. Based on these recommendations, the government issued a formal order which was implemented by the Public Service Commission in the recruitment advertisement. The court emphasized that the judicial review does not permit substitution of its own academic assessment for that of experts unless there is a clear statutory violation, manifest arbitrariness, mala fide exercise of power, or perversity.
The petitioners contended that Biotechnology had been recognized as an allied subject to Zoology in previous recruitments and that the current exclusion was arbitrary and discriminatory, especially since Biotechnology was recognized as an allied subject to Botany in the same recruitment exercise. They highlighted the substantial overlap in curricula between Biotechnology and Zoology, and the fact that the UGC regulations allow eligibility through allied or relevant subjects.
However, the court held that earlier inclusion does not create an immutable right to continued inclusion and that academic policies can be revised upon expert reconsideration. The court rejected the argument that an interim order of the Madhya Pradesh High Court recognizing Biotechnology as allied to Physiology could bind the Uttar Pradesh authorities, underscoring jurisdictional and contextual differences.
Citing precedents from the Supreme Court and prior Allahabad High Court rulings, the court reiterated the principle of judicial restraint in academic matters, highlighting that courts should be slow to interfere with academic and policy decisions made by competent authorities and expert committees.
The judgment concluded that the State Government and the Commission acted within their lawful authority and followed due process in determining the allied subjects for Zoology. As no illegality or arbitrariness was found, the writ petitions were dismissed. The court, however, allowed the petitioners to submit representations to the competent authority for reconsideration of the allied subjects list based on relevant academic material.
This ruling affirms the autonomy of educational and recruitment authorities in framing academic eligibility criteria, reinforcing that such determinations lie primarily within the domain of experts and policymakers rather than the judiciary.
Bottom Line:
Recruitment to post of Assistant Professor in Zoology - Exclusion of Biotechnology from allied/relevant subjects challenged - Determination of allied/relevant subjects is an academic and policy matter resting with expert body and State Government - Court in judicial review cannot substitute its own academic assessment merely because Biotechnology was recognised earlier or by another authority - In absence of statutory violation, manifest arbitrariness or mala fides, no interference warranted.
Statutory provision(s): Article 226, Constitution of India, UGC Regulations on Minimum Qualifications for Appointment of Teachers and Other Academic Staff in Universities and Colleges, 2018
Dr. Vartika Mishra v. State of Uttar Pradesh, (Allahabad) : Law Finder Doc Id # 2992277
