Chhattisgarh HC rules M.A. Psychology is not equal to M.A. Clinical Psychology for recruitment to Clinical Psychologist posts

News Citation : 2026 LN (HC) 135 | 2026:CGHC:2619

January 15, 2026 : The High Court of Chhattisgarh has dismissed a writ petition filed by a candidate who challenged his disqualification from the posts of Clinical Psychologist and Counsellor (Psychiatry), holding that a general Master’s degree in Psychology cannot be treated as equivalent to a Master’s degree in Clinical Psychology.

In WPS No. 216 of 2026, Justice Parth Prateem Sahu upheld the decision of the recruiting authorities to reject the candidature of Shivam Sonwani, who had applied pursuant to Advertisement No. 02/2025 dated April 22, 2025.

The advertisement, issued for multiple posts including 12 positions of Clinical Psychologist and two of Counsellor (Psychiatry), clearly required candidates to possess a postgraduate degree in Clinical Psychology or any equivalent qualification recognized by the National Medical Commission.

The petitioner, however, held an M.A. in Psychology and had studied Clinical Psychology as an optional subject during the final semesters of his course. After document verification, his name did not appear in the list of shortlisted candidates published on December 31, 2025, prompting him to approach the court.

Arguing that universities in Chhattisgarh generally award degrees under the title “M.A. (Psychology)” rather than “M.A. (Clinical Psychology),” the petitioner contended that his qualification should be treated as equivalent. He also relied on the definition of “clinical psychologist” under the Mental Healthcare Act, 2017, and cited instances where other health institutions had accepted a Master’s in Psychology for similar roles.

The Court was not persuaded. It observed that equivalence of qualifications is a technical and academic matter that must be determined by the competent authority, not by judicial interpretation. The petitioner failed to produce any document demonstrating that his M.A. (Psychology) was recognized as equivalent to an M.A. (Clinical Psychology) by the National Medical Commission.

Justice Sahu emphasized the distinction between the two degrees. While an M.A. in Psychology provides broad theoretical grounding across various branches of the subject, an M.A. in Clinical Psychology is a specialized, practice-oriented program focused on psychopathology, diagnosis, therapeutic techniques, and supervised clinical exposure. The Court held that merely studying Clinical Psychology as an optional paper does not amount to possessing a postgraduate degree in the relevant discipline.

Relying on several Supreme Court judgments, including State of Rajasthan v. Lata Arun, Ganapath Singh Gangaram Singh Rajput v. Gulbarga University, and Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad, the High Court reiterated that prescribing eligibility qualifications is the prerogative of the employer. Courts cannot expand or dilute those criteria under the guise of judicial review.

The bench also noted that the petitioner had participated in the recruitment process without challenging the eligibility criteria in the advertisement. After failing to qualify, he could not turn around and question the prescribed qualification.

Finding no arbitrariness or illegality in the rejection of the candidature, the Court dismissed the writ petition and declined to grant any relief.

Case Reference : WPS No. 216 of 2026, Shivam Sonwani vs. State of Chhattisgarh & Others; For Petitioner: Mr. Satish Kumar Sagar, Advocate; For Respondent No.1: Ms. Anuja Sharma, Deputy Government Advocate; For Respondent Nos.2 & 3: Dr. Sudeep Kumar Agrawal, Advocate; For Respondent No.4: Mr. Neeraj Choubey, Advocate.