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2026 Supreme(Online)(Mad) 8424

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
B. Pugalendhi, J
P.Priyanka – Appellant
Versus
The State of Tamil Nadu – Respondent
WP(MD)No.3209 of 2026|WMP(MD)Nos.2641 and 2642 of 2026



Advocates:
For the Appellants/Petitioners: H. Mohammed Imran
For the Respondents: M. Sarangan, T. Amjad Khan

Degrees obtained simultaneously in the same academic year, where one is from a regular stream and the other from distance education, are not recognized for appointment as per UGC guidelines and judicial precedents.

Headnote:The petitioner challenged the decision of the recruitment board to include her name in the ineligible list for the post of P.G. Assistant (Tamil) based on the pursuit of a B.Ed. degree in a regular stream and an MA degree through distance education simultaneously during the year 2017, referencing the UGC Act. The petitioner contended that the courses did not overlap as the MA course commenced after the completion of the B.Ed. degree in May 2017. The court found that the degrees were indeed pursued simultaneously in the same academic year. The central issue is whether degrees obtained simultaneously—one through a regular stream and another through distance education—are recognized for appointment. The court reasoned that, as per the University Grants Commission and established precedents, dual degrees studied simultaneously cannot be considered recognized degrees under S.22 of the UGC Act, and such qualifications cannot be considered for appointment. Accordingly, this writ petition is dismissed.

Table of Content
1. challenge to candidate ineligibility based on the simultaneous pursuit of regular and distance education degrees. (Para 1 , 2 , 3)
2. non-recognition of dual degrees obtained in the same academic year under ugc act and judicial precedents. (Para 4 , 5)
3. dismissal of the petition due to failure to meet recognized educational qualification standards. (Para 6)

PRAYER:

Writ Petitions filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus to call for the records relating to the impugned proceedings of the 3rd respondent in his proceedings NIL, dated NIL published in the official website of the TRB on 22.01.2026 and quash the same as illegal in so far as the inclusion of Petitioners name in the ineligible list is concerned and consequentially to direct the 3rd respondent to select the Petitioner for appointment to the post of P.G.Assistant (Tamil) taking to the consideration of the marks required by the petitioner in the examination within the period that may be stipulated by this Court.

ORDER

The petitioner has applied to the post of PG Assistant pursuant to the notification No.2 of 2025, dated 10.07.2025 issued by the Teachers Recruitment Board (TRB). The petitioner's candidature was rejected by the respondents on 22.01.2026 as ineligible that she has pursued PG and B.Ed., degrees simultaneously. The same is challenged in this writ petition.

2.The case of the petitioner is that she has completed B.Ed degree on regular stream in Mangayarkarasi College of Education from June 2015 to May 2017 and studied MA (Tamil), through distance education in Madurai Kamaraj University, from January 2017 to December 2018. According to the petitioner, the MA course was commenced only in the month of June 2017 and before that she has completed the B.Ed., degree in the month of May 2027. Therefore, according to the learned counsel, the degrees obtained by the petitioner cannot be treated as simultaneous degrees and hence, the impugned ineligible list has to be interfered with.

3.Mr.T.Amjad Khan, learned Standing Counsel, who takes notice for the Teachers Recruitment Board submits that the petitioner has pursued MA (Tamil) through distance in Madurai Kamaraj University during the calender years January 2017 to December 2018. The petitioner has also studied B.Ed., degree from June 2015 to May 2017. Since the petitioner was pursuing BEd., degree and MA degree simultaneously, the petitioner's candidature was rejected as ineligible. He has also relied on the judgment of the Hon'ble Full Bench of this Court in R. Chitra Vs Member Secretary, TRB, Chennai and others [2021 (3) CTC 369]

4.This Court has considered the rival submissions made.

5.The petitioner has pursued B.Ed., degree in regular stream and MA(Tamil) degreethrough distance education simultaneously in the year 2017. The Hon'ble Full Bench of this Court in R. Chitra Vs Member Secretary, TRB, Chennai and others [2021 (3) CTC 369] held that the validity of dual degrees has already been considered by the University Grants Commission and it has been declared that the dual degrees studied simultaneously cannot be considered as a degree recognised as per the provisions of Section 22 of the UGC Act . By referring to the decision of the UGC a Division Bench of this court in WA.No.845 of 2013 by order dated 07.01.2014 has held that the degrees obtained simultaneously in the same academic year one through the open university and another from regular stream will not be recognised and they cannot be considered for appointment. This view taken by the Division Bench has been approved by the Hon'ble Full Bench in R.Chitra's case.

6.In view of the above decision of the Hon'ble Full Bench, the petitioner is not entitled for appointment as PG. Assistant based on the dual degrees obtained by the petitioner simultaneously. Therefore, this court is not inclined to entertain this writ petition. Accordingly, this writ petition is dismissed. No costs.

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