The Himachal Pradesh High Court held that a postgraduate diploma cannot be treated as equivalent to a postgraduate degree for promotion to the post of Assistant Professor under the Himachal Pradesh Medical Education Service Rules, 1999. The petitioner claimed that, as per the Himachal Pradesh Medical Education Service Rules, 1999, 50% of Assistant Professor posts are to be filled through promotion of in-service doctors. He argued that his three years of teaching experience as Senior Resident after completing the postgraduate diploma should be counted towards eligibility. After examining the Service Rules, 1999, the court noted that the minimum qualification for an Assistant Professor is a postgraduate degree. The Court remarked that the rule demanded three years' teaching experience after a postgraduate degree, the petitioner's teaching experience as Senior Resident gained after a diploma but before his MD degree did not satisfy the requirement.