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2026 Supreme(Online)(Del) 1537

IN THE HIGH COURT OF DELHI AT NEW DELHI
Jasmeet Singh, J
Deep Narayan Surya Kumar Smriti Mahavidyalaya (D.El.Ed) – Appellant
Versus
National Council for Teacher Education – Respondent
W.P.(C) 696/2026 | CM APPL. 3426/2026



Advocates:
For the Appellants/Petitioners: Brijendra Singh
For the Respondents: Mohinder J.S. Rupal

Recognition granted to an educational institution for courses not under dispute cannot be withdrawn based on mere speculations or unproven allegations of forgery regarding other course capacities, especially when no formal inquiry has been conducted to establish the forgery.

Headnote:The petitioner challenged the withdrawal order dated 10.09.2025 issued by the second respondent under Section 17 of the NCTE Act, 1993, which withdrew recognition for D.El.Ed. courses on the grounds that a corrigendum increasing intake capacity from 50 to 100 seats was fake. The petitioner contended that recognition for the original 50 seats was undisputed and that no formal inquiry had been conducted to prove the forgery of the corrigendum. The court framed the issue around whether recognition for undisputed courses could be withdrawn based on mere speculations and allegations of forgery regarding additional intake without a formal investigation. The court held that since no investigation was conducted to establish the genuineness of the documents or the petitioner's role in the alleged forgery, recognition validly granted for courses not under dispute cannot be withdrawn. Accordingly, the present petition is allowed to the extent of quashing the withdrawal order dated 10.09.2025.

Table of Content
1. factual matrix involving withdrawal of recognition due to alleged fake corrigendum regarding student intake capacity. (Para 1 , 3 , 4 , 5)
2. contention that recognition cannot be withdrawn based on speculation without a formal inquiry. (Para 6 , 7)
3. undisputed recognition cannot be revoked based on unproven allegations of forgery in separate capacities. (Para 9 , 10)
4. restoration of recognition for undisputed courses and permission to participate in counselling. (Para 11 , 12 , 13)

O R D E R

% 29.01.2026 CM APPL. 3427/2026 Allowed subject to all just exceptions.

The application stands disposed of.

W.P.(C) 696/2026

1. This writ petition is filed on behalf of the petitioner under Article 226 of the Constitution of India seeking the following reliefs:-

“(a) quashing of withdrawal order dated 10.09.2025 issued by the respondentNo.2, withdrawing recognition of the D.El.Ed. courses of petitioner institution, in an arbitrary and illegal manner; and (b) direction to respondent no.2 to issue order of restoration, thereby restoring recognition of D.El.Ed. courses of the petitioner institution with all the benefits of being a recognised institute; and (c) consequent direction to respondent no.2 to update its website by displaying the recognised status of petitioner institution and communicate the same to its affiliating body and the state department of higher education; enabling the petitioner to participate in ongoing counselling and admission process.”

2. This order is being passed in view of a similar order dated 24.12.2025 passed in W.P.(C) 15781/2025, covering the present issue. Based upon the said order and using the same reasons and expressions, this order is being passed.

3. The petitioner’s case, as set out in the petition is that vide order dated

03.03.2016, Northern Regional Committee (‘NRC’) granted recognition to the petitioner institute for running D.El.Ed. course with an annual intake of 50 seats (1 unit) for academic session 2016-17. NRC issued Corrigendum dated 10.02.2017 stating therein that approved annual intake mentioned in recognition order dated 03.03.2016 in respect of the petitioner institution be read as 100 seats (2 units) in place of 50 seats (1 unit).

4. It is stated in the writ petition that before petitioner could obtain affiliation from affiliating authority for additional intake, Additional Chief Secretary, Government of UP issued a letter dated 24.08.2018 conveying that D.El.Ed. institutions were no more required in the State for the next 5 years and hence, petitioner admitted students in D.El.Ed. courses in accordance with the intake capacity originally sanctioned and no student was admitted in D.El.Ed. against additional intake pursuant to Corrigendum dated 10.02.2017. At the end of 5 years’ restriction, petitioner sought affiliation for additional intake and vide Office Memorandum dated 17.12.2024, the concerned affiliating body, granted affiliation for 100 seats (2 units) of D.El.Ed. course from academic session 2024-25 onwards in light of the Corrigendum and petitioner admitted 100 students of D.El.Ed. course for the said session.

5. It is averred that NRC in its 439th meeting held on 05th and 06th May, 2025 decided to issue show cause notice to the petitioner under Section 17 of NCTE Act, 1993 and notice was issued on 02.06.2025 alleging that Corrigendum uploaded on the portal of NRC was fake and uploaded with mala fide intent. The petitioner submitted its response vide letter dated 25.06.2025 and denied the allegations. In 443rd meeting of NRC, it considered the response of the petitioner and decided that recognition granted to the institution for D.El.Ed. courses be withdrawn under Section 17 (1) of NCTE Act with effect from the end of academic session next following the date of communication of withdrawal order and that the institution shall not admit students from academic session 2025-26 onwards. Basis this decision, impugned withdrawal order was issued on 10.09.2025, withdrawin

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