Circulars serving as reminders to staff to fulfill professional qualification mandates within a pre-determined grace period do not constitute an illegal alteration of policy and should not be set aside by courts, provided they do not shorten the established compliance timeframe.

JUDGMENT :

DEVASHIS BARUAH, J.

1. Heard Ms. V. Suokhrie, the learned Additional Advocate General appearing on behalf of the State of Nagaland and Mr. C.T. Jamir, the learned Senior Counsel assisted by Mr. I. Imchen, the learned counsel who represents the respondents in the present Appeal.

2. The present Writ Appeal is directed against the judgment and order dated 16.02.2026 passed in WP(C) No.246/2023 whereby the learned Single Judge had set aside the Circulars dated 15.03.2023 and 23.03.2023 issued by the Directorate of School Education, Nagaland.

3. The reason for doing so as it appears from the impugned judgment and order is that the Government of Nagaland had issued a Notification on 15.09.2021 whereby the untrained teachers were granted a further opportunity to undergo the required academic qualification and professional training within five years timeframe, i.e. with effect from 2022 to 2027. It was the opinion of the learned Single Judge that prior to the expiry of the said period, the impugned Circulars dated 15.03.2023 and 23.03.2023 ought not to have been issued by the Directorate of School Education, Nagaland, and as such, the said Circulars were interfered with.

4. It appears from the materials on record that the Respondents herein were appointed during the period from 2001 to 2012 and were subsequently regularized to various posts in different Government Middle Schools as Primary Hindi Teachers all over the State of Nagaland. The educational qualifications of the Respondents herein is Class VIII pass and they have undergone training/diploma in Hindi from the Hindi Teachers Training Institute at Dimapur. It is the contention of the Respondents in the writ petition that the course undergone by the Respondents, i.e. Hindi Sikshan Praveen is equivalent to Teacher’s Training Certificate/Diploma as have been acknowledged by the Government of India in its letter dated 25.11.2003. On 04.09.2017, a Press Release was issued whereby the Respondents were directed to undergo Diploma in Elementary Education and it is alleged that the Hindi Teachers who were appointed prior to 03.09.2001 were exempted from undergoing such Diploma in Elementary Education.

5. It is the further case of the Respondents herein that on 15.09.2021, a Notification was issued by the Principal Director notifying that many in-service Hindi Teachers were found untrained and as per the Finance Department’s directive, all in-service Untrained Graduate and Under- Graduate Hindi Teachers were required to acquire the requisite academic and professional qualification as per the NCTE norms. Under such circumstances, directions were issued that all untrained teachers were to obtain the required academic qualification and professional training within five years timeframe w.e.f. 2022 to 2027 which can be done from the institutions such as NIOS and IGNOU.

6. It is the case of the Respondents that on 15th of March, 2023, the Director of the Directorate of School Education had issued a Circular asking all untrained Hindi Teachers/UGT/GHT serving under the Directorate of School Education, (DSE), Nagaland, Kohima appointed after September, 2001 to submit the following necessary educational qualification documents:-

(i) UGGT: Class 10 & 12, both General and Hindi, (ii) GHT: Class 10 up to BA, both General and Hindi to the concerned DEOs/SDEOs on or before 29th of March, 2023 and the DEOs/SDEOs were requested to submit the collected documents along with the formats to the Directorate of School Education (DSE), Room No.510 on or before 6th of April, 2023.

7. Subsequent thereto, the Principal Director, Directorate of School Education issued another Circular on 23rd of A