UNION OF INDIA & ORS. vs S. B. KOHLI & ANR.

The Supreme Court held that a postgraduate degree in the concerned specialty is a necessary qualification for promotion to the post of Professor of Orthopaedic Surgery, as per the Central Health Service Rules, 1963. The Court clarified that a mere F.R.C.S. degree does not equate to a postgraduate qualification in Orthopaedics, thus rendering the promotion of the second respondent illegal. The appeal against the High Court's decision to revert the second respondent was dismissed.