Supreme Court Upholds Bihar Rule: Diploma in Pharmacy Mandatory for Government Pharmacist Jobs
Higher Degrees Not Enough, Diploma is Essential
Court Says States Can Decide Qualification Rules
By Our Legal Reporter
New Delhi: January 19, 2026:
In a landmark judgment, the Supreme Court of India has upheld the constitutional validity of the Bihar Pharmacists Cadre Rules, 2014, which make a Diploma in Pharmacy the mandatory qualification for appointment to government pharmacist posts in the state. The ruling settles a long-standing dispute between diploma holders and candidates with higher degrees such as Bachelor of Pharmacy (B.Pharm) and Master of Pharmacy (M.Pharm), who argued that their advanced qualifications should automatically make them eligible.
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The verdict, delivered by a bench of Justice M.M. Sundresh and Justice Satish Chandra Sharma, clarifies that employers — in this case, the Bihar government — have the right to prescribe qualifications for public posts. The court emphasized that higher degrees do not automatically substitute or override the minimum qualification set by the state.
Background of the Case
- The controversy began with the Bihar Pharmacists Cadre Rules, 2014, which required candidates to have 10+2 (Science) plus a Diploma in Pharmacy for entry-level pharmacist posts.
- In 2024, amendments reaffirmed this requirement, sparking protests from degree holders.
- Candidates with B.Pharm and M.Pharm degrees challenged the rules, arguing that since the Pharmacy Act, 1948 recognizes both diploma and degree holders, excluding them was discriminatory.
- The dispute reached the Supreme Court in the case MD. Firoz Mansuri & Ors. v. State of Bihar & Ors., arising out of SLP (C) No. 12236 of 2025.
Supreme Court’s Observations
The apex court made several important points:
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- Employer’s Right: The state government has the exclusive right to decide the relevancy and suitability of qualifications for a particular post.
- Diploma vs Degree: A Diploma in Pharmacy cannot be treated as an “in-line” higher qualification compared to a B.Pharm degree. They are distinct qualifications, and the state can prefer diploma holders.
- No Automatic Eligibility: Holding a higher degree does not mean automatic eligibility for a job requiring a lower qualification.
- Limited Employment Avenues: The court noted that diploma holders have limited career opportunities compared to degree holders, and reserving government posts for them ensures fairness.
Impact on Recruitment
The ruling directly affects the ongoing recruitment drive for 2,473 pharmacist posts in Bihar. Degree holders who applied without a diploma will now be excluded. This decision is expected to influence future recruitment policies in other states as well, where similar disputes may arise.
Reactions from Stakeholders
- Diploma Holders: Welcomed the judgment, saying it protects their career prospects and validates their qualification.
- Degree Holders: Expressed disappointment, arguing that their advanced knowledge and training should not be ignored.
- Legal Experts: Pointed out that the ruling reinforces the principle that policy decisions on qualifications lie within the domain of the employer, not the judiciary.
Broader Significance
This case highlights a larger debate in India’s education and employment system:
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- Should higher qualifications automatically make candidates eligible for jobs requiring lower qualifications?
- Or should states be allowed to protect diploma holders by reserving certain posts for them?
The Supreme Court’s ruling leans firmly toward the latter, emphasizing that policymaking is the prerogative of the state.
Conclusion
The Supreme Court’s decision to uphold Bihar’s rule mandating a Diploma in Pharmacy for government pharmacist posts is a turning point in public recruitment policy. It underscores the principle that higher education does not always guarantee eligibility and that states have the authority to set qualifications based on their needs.
For thousands of diploma holders in Bihar, this judgment secures their place in government service. For degree holders, it is a reminder that advanced qualifications must align with prescribed eligibility criteria.
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