Degree equivalence requires statutory authority; professional body certificates were not generally equivalent, except for a limited transitional class.

A certificate issued by a professional body cannot be treated as equivalent to a Mechanical Engineering degree unless statutory authority expressly permits such equivalence; executive recognition cannot override the governing scheme under the UGC and technical education framework. The Court therefore reaffirmed that the institution's Certificate of Membership had no general degree equivalence. A limited transitional benefit was, however, preserved for students enrolled on or before 31.05.2013, in line with later notifications and public notices recognising their position under the earlier regime. Beyond that cut-off date, the certificates remained outside degree equivalence.

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Issues: (i) Whether the Certificate of Membership issued by the institution could be treated as equivalent to a degree in Mechanical Engineering for all purposes. (ii) Whether the benefit of equivalence could be extended to students enrolled up to 31.05.2013 notwithstanding the general rejection of equivalence.

Issue (i): Whether the Certificate of Membership issued by the institution could be treated as equivalent to a degree in Mechanical Engineering for all purposes.

Analysis: The institution did not confer degrees within the meaning of the University Grants Commission Act, 1956 and did not fall within the categories empowered to grant degrees under Section 22(1). The field of technical education was also within the regulatory domain of the All India Council for Technical Education Act, 1987, which empowered the regulator to lay down norms and advise on chartered powers for professional bodies. In the absence of any statutory provision authorising equivalence to be conferred on the institution's certificates, such certificates could not, as a matter of law, be treated as degrees. Executive recognition earlier granted could not override the statutory scheme.

Conclusion: The Certificate of Membership could not be treated as equivalent to a degree in Mechanical Engineering for all purposes.

Issue (ii): Whether the benefit of equivalence could be extended to students enrolled up to 31.05.2013 notwithstanding the general rejection of equivalence.

Analysis: The Central Government and the regulatory authority had, by later notifications and public notice, acknowledged a transitional arrangement for students enrolled up to the specified date. The record showed that such students had joined under a regime of governmental recognition and that the later communications preserved their position up to the cut-off date. The Court therefore carved out a limited exception confined to those enrolled on or before 31.05.2013, without disturbing the general rule that the certificates were not equivalent to degrees beyond that date.

Conclusion: The benefit of equivalence was confined to students enrolled up to 31.05.2013.

Final Conclusion: The challenge failed in substance, and the Court sustained the view that the institution's certificates did not carry degree equivalence generally, while preserving a limited transitional benefit for the specified class of students.

Ratio Decidendi: A certificate issued by a professional body cannot be treated as equivalent to a university degree unless such equivalence is supported by statutory authority; executive recognition may operate only within the limits of the governing statute and any expressly preserved transitional regime.

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