Physiotherapy Degree Not Equivalent to MBBS, Says Allahabad High Court While Dismissing Petition of Food Safety Officer Aspirant


By Rajesh Pandey

In a recent judgment dated July 4, 2025, the Allahabad High Court clarified that a Bachelor’s degree in Physiotherapy (BPT) cannot be treated as equivalent to an MBBS degree, particularly when such equivalence is not recognized by the State Government or a competent medical regulatory authority.

The court ruled that determining such academic equivalency falls outside the scope of its writ jurisdiction under Article 226 of the Constitution.

The judgment was delivered by Justice Ajit Kumar, who was hearing a writ petition filed by one Sandhya Yadav.

The petitioner had challenged her exclusion from the interview stage for the post of Food Safety Officer (FSO), a recruitment process conducted by the Uttar Pradesh Public Service Commission (UPPSC) under an advertisement dated July 14, 2014.


Petitioner’s Claim and Court’s Ruling

Sandhya Yadav had appeared for the written examination conducted by the UPPSC and successfully cleared it. Following her success, she was issued a call letter for the interview, leading her to believe that she had fulfilled all eligibility criteria as per the recruitment rules.

 

However, when she approached the commission for the interview round, she was informed that she was ineligible as she did not possess a Bachelor’s degree in Medicine, which was listed as a mandatory qualification in the recruitment notification.

Her Bachelor of Physiotherapy (BPT) degree was deemed insufficient under the Food Safety Officer Service Recruitment Rules, 2012, which explicitly require a bachelor’s degree in medicine or medical science.

 

Feeling aggrieved, she approached the Allahabad High Court, arguing that her qualification in physiotherapy should be considered equivalent to a medical degree, and therefore, she should have been permitted to complete the recruitment process.


No Jurisdiction to Declare Equivalence: High Court

In his judgment, Justice Ajit Kumar made it clear that the High Court does not possess the authority under its writ powers to declare academic degrees as equivalent, particularly when such matters fall within the purview of executive or expert medical bodies.

 

“It is either for the State Government to recognize such a degree of physiotherapy as equivalent to the bachelor’s degree in medicine, or for the Medical Council of India to declare a course of physiotherapy as being in the domain of medicine,” the court stated.

 

“Unless and until the State Government recognizes it as such, or the appointing authority under the relevant service rules accepts such qualification, the court cannot direct the authority to treat it as equivalent to the prescribed medical degree,” the order emphasized.


Commission’s Position and Final Verdict

The UPPSC, in its defense, submitted that as per communication from the Director (Enforcement) of the Food Safety and Standards Authority, dated June 30, 2014, no alternate or equivalent qualification to MBBS had been notified by the Central Government.

Accordingly, based on this information and the terms laid down in the advertisement, the Commission concluded that Bachelor in Physiotherapy did not meet the qualification standards for the FSO post, which clearly required a degree in medicine.

Upholding the commission’s decision, the court stated:

“The degree possessed by the petitioner, being a Bachelor in Physiotherapy, is not a Bachelor in Medicine, as stipulated under the 2012 recruitment rules.”

Additionally, the court highlighted that the recruitment process pertains to an advertisement issued in 2014, and the final results were declared on January 29, 2015. Given that the selection process has already concluded, the court emphasized that it cannot reopen the matter after such a significant lapse of time.

 

“Once a selection process has been completed, the Court cannot now permit its reopening,” the judge firmly stated.

With this ruling, the Allahabad High Court has reaffirmed that equivalence of academic qualifications must be determined by statutory authorities such as the State Government or the Indian Medical Association, and not by judicial intervention under Article 226.

The petitioner’s plea to have her BPT degree treated on par with MBBS was dismissed, setting a precedent that academic qualifications must align strictly with service rules, unless officially notified otherwise by competent authorities.

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