THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH)
Budi Habung, J.
Miss Ishak Phassang and Ors. – Petitioners
Versus
The State of AP represented by the Chief Secretary and Ors. – Respondents
WP(C) 509 of 2025
Decided On : 18-05-2026
| Table of Content |
|---|
| 1. factual background concerning eligibility criteria for pgt recruitment. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8) |
| 2. parties' contentions regarding the enforceability of recruitment rules versus administrative errors. (Para 9 , 10 , 11) |
| 3. administrative mistakes cannot override statutory rules and b.ed special is not equivalent to general b.ed for general teaching roles. (Para 12 , 13 , 14 , 15) |
| 4. dismissal of the petition and vacation of interim relief. (Para 16 , 17 , 18) |
JUDGMENT :
BUDI HABUNG, J.
Heard Mr. C. Modi, learned counsel for the petitioners. Also heard Ms. P. Pangu, learned Government Advocate for State respondent No. 1; Ms. N. Anju, learned Standing Counsel, APPSC, for the respondent Nos. 2 and 3; and Mr. T. Tagum, learned Standing Counsel, Education Department, for the respondent Nos. 4 and 5.
2. The present writ petition has been filed by the petitioners, numbering 100, challenging the notification dated 28.10.2025 issued by the Arunachal Pradesh Public Service Commission (hereinafter referred to as “APPSC”), whereby candidates possessing B.Ed. (Special)/B.Ed. (Special Education) were declared ineligible for appointment to the post of Post Graduate Teacher (PGT) under the Education Department.
3. The facts of the case, in brief, are that the Arunachal Pradesh Public Service Commission issued an advertisement dated 16.08.2025 inviting applications for filling up 111 posts of Post Graduate Teacher (PGT) under the Education Department, Government of Arunachal Pradesh. As per the PGT Recruitment Rules, 2014, as well as the advertisement dated 16.08.2025, the prescribed educational qualification for the post of PGT was “Second Class Master’s Degree in the concerned subject from a recognized university with B.Ed.”
4. The petitioners possess a Second Class Master’s Degree in the concerned subject along with B.Ed. (Special Education)/B.Ed. (Special). On the basis of the said qualifications, the petitioners submitted their applications, and admit cards were issued to them during the month of September, 2025.
5. Subsequently, the Public Service Commission, by letter dated 09.10.2025, wrote to the Commissioner, Education Department, seeking clarification as to whether candidates possessing B.Ed. (Special Education), B.Ed. (Special Education–Learning Disability), B.Ed. (Special Education – Hearing Impairment), and B.Ed. (Special) were eligible to apply for the post of Post Graduate Teacher (PGT).
6. In response thereto, the Commissioner (Education), Government of Arunachal Pradesh, by letter dated 15.10.2025, clarified that, as per the PGT Recruitment Rules, the minimum educational qualification prescribed for the post of Post Graduate Teacher (PGT) is a Second Class Master’s Degree in the concerned subject from a recognized university with B.Ed. Hence, candidates possessing any other qualification would not be considered eligible for the posts. It was further clarified that the NCTE Regulations, 2014, notified on 12.11.2024, have laid down the minimum academic and professional qualifications for recruitment of teachers at the secondary/higher secondary and senior secondary levels, and B.Ed. (Special Education) has not been recognized as an alternative teacher education qualification for teaching Classes IX to XII. Accordingly, only the general B.Ed. qualification is acceptable for the post in question.
7. Pursuant to the said clarification, the Commission issued the impugned notification dated 28.10.2025 clarifying that, other than candidates possessing a general B.Ed. degree, candidates possessing qualifications such as B.Ed. (Special Education), B.Ed. (Special), or any qualification other than a general B.Ed. would be treated as ineligible for the posts of Post Graduate Teacher (PGT). It was further stated that if any candidate is found to possess B.Ed. (Special Education), B.Ed. (Special), or any other degree other than a general B.Ed. upon further verification, the Commission reserves the right to withhold their
Administrative errors, such as the inadvertent issuance of admit cards, cannot override statutory recruitment rules. Eligibility criteria prescribed by law must be strictly adhered to, and parity can....
B.Ed. (Special) qualification recognized by NCTE is equivalent to B.Ed. General, ensuring equal opportunity for candidates with disabilities in educational recruitment processes.
The Supreme Court ruled that B.Ed. is not a valid qualification for primary school teachers, affecting eligibility for appointments made after its decision.
The court established that D.El.Ed. is the sole qualification for primary school teachers, invalidating B.Ed. as a qualification and affirming the prospective application of its ruling.
Login now and unlock free premium legal research
Login to SupremeToday AI and access free legal analysis, AI highlights, and smart tools.
Login
now!
India’s Legal research and Law Firm App, Download now!
Copyright © 2023 Vikas Info Solution Pvt Ltd. All Rights Reserved.