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2025 Supreme(Online)(Mad) 53398
IN THE HIGH COURT OF JUDICATURE AT MADRAS
L.Victoria Gowri, J
The Secretary, St. Justin's College of Education – Appellant
Versus
The National Council for Teacher Education – Respondent
W.P.(MD).No.28024 of 2024 | W.M.P.(MD)Nos.23772 and 23773 of 2024
For the Appellants/Petitioners: Sr.A.Amala
For the Respondents: Mr.Gowri Shankar, Mr.T.Amjad Khan, Mr.F.Deepak
Educational institutions must comply with specified faculty qualifications under NCTE regulations to obtain and maintain course recognition, failure leading to denial of additional intake.
Headnote:(A) National Council for Teacher Education Act, 1993 - Section 32 - Writ petition under Article 226 of the Constitution - Challenge to denial of recognition for B.Ed. and M.Ed. programmes - College sought restoration of recognition after earlier withdrawal - NCTE regulations required faculty qualifications - Court quashed impugned minutes partially, restoring recognition for first unit of B.Ed., programme, but maintained reduced recognition for M.Ed. (Paras 41-45)
(B) Educational Institutions - Recognition - Institutions must comply with statutory norms regarding faculty qualifications for course recognition - Failure to meet eligibility requirements leads to denial of additional recognition (Paras 21, 22, 41).
Facts of the case:
The petitioner, a minority education institution, sought recognition for B.Ed. and M.Ed. courses after initial denial by SRC of NCTE based on faculty ineligibility. The college argued for restoration claiming qualifications were met and admissions were hindered unjustly.
Findings of Court:
Recognition for existing degree programmes was restored, underscoring the necessity of compliance with NCTE regulations while denying new intake until compliance confirmed.
Issues: The primary issue was whether the recognition could be restored based on alleged compliance with statutory requirements and past denials of recognition affecting student admissions.
Ratio Decidendi: The court affirmed the necessity for compliance with NCTE regulations, stressing educational integrity and public interest, while aligning with procedural rectifications; decisions of regulatory bodies must reflect statutory adherence.
Result: Writ petition partly allowed, restoring recognition for B.Ed. first unit while maintaining decision for M.Ed. course.
| Table of Content |
|---|
| 1. court reserves judgment order delivery. (Para 1) |
| 2. institution's history and recognition process. (Para 2 , 3 , 4 , 5) |
| 3. withdrawn recognition and subsequent actions. (Para 6 , 7) |
| 4. court proceedings and interim orders related to admissions. (Para 8 , 9) |
| 5. further writ petitions and their outcomes. (Para 10 , 11) |
| 6. dismissal of writ petitions for forum shopping. (Para 12) |
| 7. analysis of regulations and faculty adequacy. (Para 13 , 14) |
| 8. refusal of recognition due to faculty issues. (Para 15 , 18 , 19 , 20 , 21) |
| 9. challenging grounds against recognition outcomes. (Para 22) |
| 10. chain of events leading to current proceedings. (Para 23) |
| 11. final decision regarding recognition status. (Para 24 , 25) |
| 12. conclusions of the final order. (Para 26 , 27 , 28) |
| 13. court's recognition decisions and regulations interpretations. (Para 32 , 33 , 34 , 35 , 36 , 37) |
ORDER
This writ petition is filed to call for the records relating to the impugned minutes of the 444th SRC meeting held on 15th - 16th October 2024 in so far as Serial No.62 File No.AOSO0442, APSO6134, quash the same in so far as denying the recognition for petitioner's college for conducting B.Ed., programme (2 basic units) and M.Ed., programme w.e.f., the academic year 2025-2026 and further direct the respondents 1 and 2 to issue continuation of recognition for the petitioner college for conducting for B.Ed., programme (2 basic units) and M.Ed., programme from the academic year 2024-2025 onwards based on the detailed proposal submitted by the college on 25.10.2024.
2.The Petitioner Institution is a recognized minority educational institution established in the year 1968 and duly recognized by the first respondent, namely, the National Council for Teacher Education (hereinafter to be referred as NCTE). The petitioner institution is running B.Ed., and M.Ed., degree courses both under the aided and under the self-financing scheme. The first respondent / NCTE is responsible for maintaining norms and standards for teacher education across the country. The second respondent, Southern Regional Committee (hereinafter to be referred as SRC) is responsible for the grant of recognition to teacher education institutes in the State of Tamil Nadu. The petitioner institution applied before the second respondent for grant of recognition to conduct the B.Ed., course. After processing the application of the petitioner institution, the second respondent issued a certificate of recognition order on 03.09.1996 to the petitioner institution for running the B.Ed., course of one year duration with an annual intake of 100 seats.
3.While being so, the NCTE in exercise of its powers conferred under Section 32 of the NCTE Act, 1993 , framed NCTE (recognition norms and procedure) regulations, 2007, which came into force with effect from 16.12.2007, which provides for the manner of making an application by a teacher training institute and processing thereof by the regional committee concerned. Following which the petitioner college applied before the SRC / second respondent for grant of recognition to conduct the M.Ed., course. After processing the application of the petitioner institution, the second respondent issued a certificate of recognition order on 09.08.2007 to the petitioner institution for running the M.Ed., course with a duration one year with an annual intake of 25 seats at the first instance. Thereafter, the petitioner institution further made an application for grant of recognition to conduct the B.Ed., course, that is, the second basic unit before the second respondent. After processing the application of the petitioner institution, the second respondent issued a recognition order dated 28.04.2009 granting recognition to the petitioner institution for running the second basic unit of B.Ed., course with an annual intake of 100 seats.
4.Thus, the recognition order dated 28.04.2009 made the petitioner college eligible for a total intake of 100 seats, that is one basic unit under the
