Telangana HC Sets Aside TSPSC Rejection of Candidates Holding Bethesda Institute Certificates for Sanitary Inspector Posts
Justice T. Madhavi Devi found that TSPSC's Expert Committee gave no reasons for rejecting certificates from Bethesda Institute of Health Sciences, whose de-recognition had been suspended by a subsisting High Court interim order since 2008.
The High Court for the State of Telangana at Hyderabad has allowed two writ petitions filed by candidates who were denied appointment as Sanitary Inspector and Health Assistant after the Telangana State Public Service Commission (TSPSC) rejected their training certificates from Bethesda Institute of Health Sciences, Visakhapatnam. Justice T. Madhavi Devi, sitting singly, set aside the rejection memos issued by TSPSC and directed the respondents to reconsider the petitioners' cases for appointment in available vacancies with all consequential benefits. The court found that the Expert Committee's report lacked any reasoning, and that a Government of Telangana letter from October 2025 confirmed that the course “Public Health & Sanitation Technology” carries the same National Classification of Occupations code as the Sanitary Inspector course.
The Dispute Before the High Court
The two petitions arose from a selection process conducted by TSPSC under Notification No. 19/2018 and Notification No. 20/2018, both dated 27 July 2018, for the posts of Sanitary Inspector and Health Assistant in municipalities under the Municipal Administration and Urban Development Department.
The petitioner in W.P. No. 27814 of 2019, J. Rajitha, had passed B.Sc. (BZC) in 2011 and also held a Public Health and Sanitation Technology certificate from Bethesda Institute of Health Sciences, Visakhapatnam, obtained in 2012. She secured State Rank 7 for the post of Health Assistant and Rank 12 for Sanitary Inspector, standing first in the women's quota in both. The petitioner in W.P. No. 27205 of 2019, a BC-A candidate who is also physically challenged, secured Rank 124 and likewise held a certificate from Bethesda Institute in Public Health and Sanitation Technology.
Both petitioners were called for certificate verification. TSPSC declined to consider their candidatures on the ground that Bethesda Institute of Health Sciences, Visakhapatnam had not been recognised by the Andhra Pradesh Para Medical Board and that the course they had completed, Public Health and Sanitation Technology, was not the same as the prescribed Sanitary Inspector Training Course or Multi Purpose Health Assistant Training Course.
TSPSC issued rejection memos bearing No. 556/Rectt-pool-II/3/2015, one in January 2020 and another dated 4 January 2020, formally communicating the disqualification to each petitioner. The writ petitions challenged those memos as illegal and arbitrary, seeking a direction to declare the petitioners selected and appoint them.
Prescribed Qualifications and the Certification Dispute
Notification No. 19/2018 prescribed two qualifications for the post of Sanitary Inspector: a Bachelor's degree in Biological Science from a recognised university, and a Sanitary Inspector Training Course certificate awarded by the Chairman, Board of Examinations constituted by the Government of Telangana or from a Government of India or Government of Telangana recognised institution, as specified in G.O.Ms. No. 84, MA&UD (G1) Department, dated 14 February 2012.
For the post of Health Assistant under Notification No. 20/2018, the prescribed qualification included an Intermediate with Biological Science and a pass certificate in Multi Purpose Health Assistant Training Course or Sanitary Inspector Training Course from a recognised institution, as specified in G.O.Ms. No. 84 and G.O.Ms. No. 161, MA&UD Department, dated 1 June 2016.
TSPSC's position, set out in its counter affidavit, was that the petitioners had completed a course titled Public Health and Sanitation Technology, which was distinct from the prescribed training courses. The commission also relied on a Supreme Court ruling in Civil Appeal No. 4597 of 2019 to the effect that essential qualifications for a post are for the employer to decide, and that TSPSC itself had no authority to alter or include qualifications, those being governed by the Special Rules and Service Rules prescribed by the Government.
An Expert Committee had been constituted to examine the certificates submitted by candidates. According to TSPSC, the committee examined the petitioners' certificates and concluded they did not possess the prescribed qualification.
The Petitioners' Case: Interim Orders, Government GOs, and RTI Data
The petitioner in W.P. No. 27205 of 2019 filed a reply affidavit on 18 February 2026 setting out a detailed legislative and litigation history around Bethesda Institute's recognition.
According to the reply affidavit, the Government of India had recognised the Public Health and Sanitary Technology certificate from Bethesda Institute vide G.O.Ms. No. 84, Health, Medical and Family Welfare (J2) Department, dated 26 March 2002, adding it as a qualification for the post of Health Assistant. The Government of Telangana adopted this qualification vide G.O.Ms. No. 161, Municipal Administration and Urban Development (D2) Department, dated 1 June 2016.
The Government of Andhra Pradesh subsequently issued G.O.Ms. No. 23 dated 23 January 2008 de-recognising the qualification awarded by Bethesda Institute. Bethesda Institute challenged that order in W.P. No. 1790 of 2008, and the High Court granted an interim suspension of the de-recognition proceedings. The Government then issued G.O.Rt. No. 219 dated 21 June 2008 omitting Bethesda Institute's certificates from the rules. That order was also challenged in W.P. No. 15722 of 2008, and the High Court suspended that G.O. on 22 July 2008. The Government subsequently issued G.O.Ms. No. 30 dated 9 February 2012 and a consequential memo dated 27 February 2013 permitting Bethesda Institute to impart training, subject to the outcome of W.P. No. 1790 of 2008. That writ petition was still pending as of the date of the reply affidavit.
The petitioner also placed on record information obtained under the Right to Information Act showing that persons holding the very same certificates from Bethesda Institute had not only been appointed but had also been promoted as Health Assistants. The petitioners argued that the Expert Committee had not genuinely examined their certificates and that its report was vague and non-speaking.
How the Bench Reasoned
Justice T. Madhavi Devi identified the core question as whether the petitioners possessed the necessary qualification and whether the certificate from Bethesda Institute was valid.
On the question of the institute's recognition, the court observed that the de-recognition of Bethesda Institute had been suspended by interim orders in W.P. No. 1790 of 2008 and that those interim orders were still subsisting. Consequently, the certificates issued by the institute had to be treated as valid and could not be disregarded.
On the question of course equivalence, the court referred to a letter from the Government of Telangana bearing No. J/D/607/2025 dated 28 October 2025. That letter stated that as per available records and information furnished, the National Classification of Occupations (NCO-2015) lists the course “Public Health & Sanitation Technology” under Code 089.30, which is the same code as the Sanitary Inspector course, and that both courses are therefore treated as the same under the NCO codes issued by the Government of India. The same letter also confirmed that TSPSC is not the competent authority to decide on eligibility criteria, qualifications, or eligibility conditions, those being decided by the respective departments as per the job chart and service rules.
The court found that the Expert Committee's report did not disclose whether the rejection was on account of non-recognition of the institute or on account of the petitioners not possessing the necessary qualification. The reasons for the committee's conclusion were missing from the report. Given that the NCO-2015 classification treated both courses as identical, the court held that the petitioners ought to have been considered by TSPSC, and that at the very least TSPSC ought to have sought a clarification from the competent department before rejecting the candidatures.
Order
Justice T. Madhavi Devi set aside the impugned memos bearing No. 556/Rectt-pool-II/3/2015 dated January 2020 and dated 4 January 2020 issued by TSPSC, Hyderabad. The respondents were directed to reconsider the cases of both petitioners for appointment in available vacancies with all consequential benefits. Both writ petitions were allowed. No order as to costs was made. Pending miscellaneous petitions, if any, in the two writ petitions were directed to stand closed.