BBA Counts As Commerce Graduation: Madhya Pradesh High Court Quashes Rejection of Candidate

The Madhya Pradesh High Court has held that a Bachelor of Business Administration (BBA) degree can be treated as equivalent to a commerce graduation for recruitment purposes, setting aside the rejection of a candidate for the post of Assistant Accountant and directing the authorities to grant him appointment with consequential benefits.

The ruling came in a writ petition filed by Sarvesh Dhingra, whose candidature for the post of Assistant Accountant under the Urban Administration and Development Department had been cancelled on the ground that he did not possess a B.Com degree. The petition was heard by Justice Anand Singh Bahrawat at the Gwalior Bench, who found that the rejection was not in consonance with the terms of the advertisement or the applicable recruitment rules.

Appearing for the petitioner, Advocate Dharmendra Singh Raghuvanshi argued that the advertisement only required a “graduate in commerce” with computer knowledge, and did not specifically mandate a B.Com degree. It was further contended that the petitioner held a BBA degree and had also obtained a certificate from the Commerce Department of Jiwaji University, Gwalior, certifying that BBA is equivalent to a commerce graduate qualification.

On the other hand, Government Advocate Prabhat Pateriya opposed the petition, contending that BBA and B.Com are distinct degrees with different subject structures, and that eligibility for admission to M.Com does not automatically establish equivalence for employment purposes.

After considering the rival submissions and examining the record, the court noted that the advertisement did not prescribe B.Com as an essential qualification. Instead, it only required graduation in commerce. The court further relied on the certificate issued by the Dean of the Faculty of Commerce at Jiwaji University, which clearly stated that “we give our acceptance that B.B.A. is equivalent to commerce graduate.”

The court observed that once an expert academic body has certified equivalence, the authorities cannot arbitrarily disregard such a determination. It emphasised that the recruitment rules also supported this interpretation. While the rules specifically required a B.Com degree for the post of Assistant Accounts Officer, they only mandated “graduation in commerce” for the post of Assistant Accountant/Cashier.

In a significant observation, the court held that “when expert body has already given certificate stating that B.B.A. is equivalent to commerce graduate then respondents cannot reject the candidature of petitioner.” It further reiterated the settled principle that courts should ordinarily defer to expert opinion in academic matters, noting that “it would be wise and safe for the Court to leave the decision of academic matter to experts.”

Applying these principles, the court concluded that the petitioner fulfilled the eligibility criteria and that the rejection of his candidature was unjustified. It accordingly quashed the impugned order dated January 30, 2018.

The court went a step further and directed the State authorities to grant the petitioner all consequential benefits. These include appointment to the post of Assistant Accountant, seniority, increments, and placement in the seniority list in accordance with his merit position. Recognising that the petitioner was not at fault, the Court also awarded 50 percent back wages, observing that he had been wrongfully denied appointment despite possessing the requisite qualifications.

The authorities have been directed to complete the entire exercise within three months from the date of receipt of the certified copy of the order.

Case Title: Sarvesh Dhingra v. State of Madhya Pradesh and Others

Date of Order: March 12, 2026

Bench: Justice Anand Singh Bahrawat