STATE OF M.P. vs DHARAM BIR

The Supreme Court held that mere experiential knowledge cannot substitute for the requisite educational qualifications for the post of Principal, Class II, as mandated by the Madhya Pradesh Industrial Training (Gazetted) Service Recruitment Rules, 1995. The Court found that the respondent, lacking a Degree or Diploma in Engineering, was improperly promoted to Principal and upheld the Departmental Promotion Committee's decision to appoint him as Vice-Principal instead. The ruling clarified that the educational qualifications apply to promotions as well as direct recruitment under Article 302 of the Constitution.