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2026:MHC:3007 WP No. 24215 of 2018 __________ Page1 of 9 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 15-07-2026 CORAM THE HON'BLE MR JUSTICE S. M. SUBRAMANIAM AND THE HON'BLE MR.JUSTICE N.SENTHILKUMAR WP No. 24215 of 2018, WP NO. 23829 OF 2018 and WP NO. 31008 OF 2022 WP No. 24215 of 2018
1. K.Vijayakumar,
2. K.Narasimmarajan
3. B.Navaneethan
4. J.Yogesh
5. P.Francis ..Petitioner(s) Vs
1. The Secretary Tamil Nadu Public Service Commission, TNPSC Road, V.O.C. Nagar, Park Town, Chennai – 600003
2. The Secretary Department of Environment & Forest, Government of Tamil Nadu, Fort St. George, Chennai - 600009 ..Respondent(s) WP No. 23829 of 2018 K.Srinivasan ..Petitioner(s) Vs
1. The Secretary Tamil Nadu Public Service Commission, TNPSC Road, V.O.C.Nagar, Park Town, https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page2 of 9 Chennai - 600003
2. The Secretary Department of Environment & forest, Namakkal Kavignar maaligai, Governmentt of Tamil Nadu, Fort St. George, Chennai -9 ..Respondent(s) WP No. 31008 of 2022 K.Srinivasan ..Petitioner(s) Vs
1. The Secretary Tamil Nadu Public Service Commission, TNPSC Road, VOC Nagar, Part Town, Chennai-03, Tamil Nadu, India. 2. the Secretary Department of Environment and Forest, Namakkal Kavignar Maaligai, Govt of Tamil Nadu, Fort St. George, Chennai-09, Tamil Nadu, India. ..Respondent(s) WP No. 24215 of 2018 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 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”. WP No. 23829 of 2018 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 https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page3 of 9 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”. WP No. 31008 of 2022 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. WP No. 24215 of 2018 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 WP No. 23829 of 2018 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 WP No. 31008 of 2022 For Petitioner(s): Mr.K.Venkatramani Senior Counsel for Mr.M.Vignesh Raj https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page4 of 9 For Respondent(s): Mr.K.Karthik Jagannath, Standing Counsel for TNPSC for R1, Dr.R.Gouri, Government Counsel for R2 Common Order (Order of the Court was made by S.M.Subramaniam J.) 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 1st respondent to re-issue a fresh notification including M.Sc. Wildlife Biology degree as preferred degree or equivalent degree to B.Sc. Forestry for recruitment to the post of Forest Apprentice. 2. 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 of the year 2017, qualification fixed for the post of forest apprentice is 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 https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page5 of 9 OR (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
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 item
(b)
will
be considered for selection process in the respective communal categories. https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page6 of 9
3. 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 47th meeting held on 04.03.2014 submitted its recommendations. Government accepted the resolution/recommendation of the 47th 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. 4. Learned counsel for the petitioners would submit that M.Sc.
Wildlife 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. https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page7 of 9
5. This Court is of the considered view that grant of equivalence 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 the equivalence between the two degrees granted by the Universities. 6. That apart, recruitment notification was issued in the year 2018 and process of selection concluded long before. Selected candidates were appointed and working for the past several years. 7. Under these circumstances, the writ petitioners are not entitled for any further relief from the hands of this Court. 8. 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” https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page8 of 9
9. This Court has already considered the issue regarding grant of 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. 10. Accordingly, the writ petitions are dismissed. No costs. Consequently, the connected miscellaneous petitions, if any, are closed. (S.M.S.,J.) (N.S.,J.) 15-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No GD To
1. The Secretary Tamil Nadu Public Service Commission, TNPSC Road, V.O.C. Nagar, Park Town, Chennai - 600003
2. The Secretary Department of Environment & Forest, Government of Tamil Nadu, Fort St. George, Chennai - 600009 https://www.mhc.tn.gov.in/judis
2026:MHC:3007 WP No. 24215 of 2018 __________ Page9 of 9 S.M.SUBRAMANIAM J. AND N.SENTHILKUMAR J. GD WP No. 24215 of 2018, WP NO. 23829 OF 2018 and WP NO. 31008 OF 2022 15-07-2026 https://www.mhc.tn.gov.in/judis