Physiotherapy Degree Not Equivalent to Medicine: Allahabad High Court Upholds UPPSC’s Candidate Rejection

In a significant ruling, the Allahabad High Court has upheld the Uttar Pradesh Public Service Commission’s (UPPSC) decision to bar a candidate holding a Bachelor’s degree in Physiotherapy from appearing in an interview for the post of Food Safety Officer. The court ruled that a degree in Physiotherapy cannot be treated as equivalent to a “degree in medicine” under the applicable service rules.

The bench of Justice Ajit Kumar dismissed the writ petition filed by Sandhya Yadav, who had challenged the Commission’s rejection of her candidature despite clearing the written examination. The case turned on the interpretation of eligibility criteria laid out in the U.P. Food Safety and Drug Administration Department (Food Safety Cadre) Service Rules, 2012, which prescribe a “degree in medicine” as one of the qualifications for the post.

The petitioner, a graduate in Physiotherapy from Integral University, Lucknow, argued that her qualification fell within the broader ambit of medicine. Her counsel submitted that the University Grants Commission (UGC), in a 2014 notification, had recognized Physiotherapy under the “Health and Allied Sciences” category. Furthermore, the petitioner contended that her curriculum included subjects like surgery, neurology, orthopaedics, and rehabilitation, qualifying it as modern scientific medicine.

However, court sided with the UPPSC and the state government, which argued that only a Bachelor of Medicine and Bachelor of Surgery (MBBS) degree recognized under the Indian Medical Council Act, 1956, fulfills the requisite academic criterion. The Medical Council of India had not recognized Physiotherapy as equivalent to a degree in medicine, and neither the State nor Central Government had issued any notification declaring it as such.

Quoting previous judgments, court reiterated that determining equivalence of qualifications is not within the court’s domain but lies solely with expert bodies and government authorities. “This court will not direct the authority to consider degree in question as a qualification at par with graduate bachelors degree in medicine as required under the relevant Service Rules,” court stated.

However, court stated that it could have considered the prayer of the petitioner and refer the matter to the State Government for considering and passing appropriate orders regarding equivalence qua bachelors in medicine degree or for that matter to the Central Government, but no such prayer was made.

Court further noted that the recruitment process in question was from 2014 and had long since concluded.

The petition was accordingly dismissed.

Case Title: Sandhya Yadav vs. State Of U.P. And 2 Ors.

Download judgment here