Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(Tri) 329

HIGH COURT OF TRIPURA AGARTALA

W.P.(C)No.445 of 2025

1. Smt. Sabita Barman,

D/O: Binu Barman, R/O: East Pratapgarh,

P.O: Agartala, P.S: East Agartala,

Dist: West Tripura,

PIN: 799003, Aged about 45 years approx.

2. Smt. Sangita Das,

D/O: Lt. Atul Kumar Das,

R/O: Vill: Kalachari, P.O: Garad Tilla,

P.S: Kamalpur, Dist: Dhalai,

PIN: 799285, aged about 44 years approx.

3. Smt. Sangita Banik,

W/O: Suman Banik, R/O: A.D Nagar, Road No. 1,

P.O & P.S: A.D Nagar, Dist: West Tripura,

PIN: 799003, aged about 40 years approx.

4. Smt. Piyali Benerjee,

D/O: Sri Prashanta Banerjee,

R/O: Battala to Dashamighat Road, Near Snehamayi Ashram,

P.O: Agartala, P.S: West Agartala,

Dist: West Tripura, PIN: 799001, aged about 44 years approx.

5. Sri Debajit Das,

S/O: Sri Pulin Das, R/O: Vill: Garurband,

P.O: Urmai, P.S: Sonamura,

Dist: Sepahijala, PIN: 799115, aged about 37 years approx.

6. Sri Dipankar Majumder,

S/O: Sri Shyamal Ranjan Majumder,

R/O: Master Para, Town Bordowali, P.O: Agartala,

P.S: West Agartala, Dist: West Tripura,

PIN: 799001, aged about 42 years approx.

7. Smt. Mandira Das,

W/O: Rajib Roy, R/O: Dakbanglow Road,

P.O: R.K Pur, P.S: R.K Pur, Dist: Gomati,

PIN: 799120, aged about 37 years approx.

8. Smt. Ratna Majumder Chowdhury,

W/O: Partha Chowdhury, R/O Vill: Satmura Chowmuhani,

P.O: & P.S: Belonia, Dist: South Tripura,

PIN: 799155, aged about 50 years approx.

….Petitioner(s).

Versus

1. The State of Tripura, Represented by it's Special Secretary,

School Education Department, Govt. of Tripura,

P.O: Secretariat, P.S: New Capital Complex,

Dist: West Tripura, PIN: 799010.

2. The Director of Secondary Education,

Directorate of Secondary Education, Govt. of Tripura,

P.O: Agartala, P.S: West Agartala,

Dist: West Tripura, PIN: 799001.

3. Teachers Recruitment Board, Tripura, represented by it's Member Secretary,

Siksha Bhawan, Office Lane,

P.O: Agartala, P.S: West Agartala,

Dist: West Tripura, PIN: 799001.

4. The Controller of Examinations,

Teachers Recruitment Board, Tripura, Siksha Bhawan, Office Lane,

P.O: Agartala, P.S.: West Agartala,

Dist: West Tripura, PIN: 799001.

..... Respondents.

For Petitioner(s) : Mr. Arijit Bhaumik, Adv.

For Respondent(s) : Mr. Karnajit De, Addl. G.A.

Date of Hearing : 10.03.2026

Date of delivery of Judgment and Order : 01.04.2026

Whether fit for Reporting : YES/NO

HON’BLE MR. JUSTICE BISWAJIT PALIT

Advocates:
For the Appellants/Petitioners: Arijit Bhaumik
For the Respondents: Karnajit De

Where a specialized administrative committee is established to determine the equivalence of professional degrees, the failure to address representations regarding such parity is deemed arbitrary. Public authorities are mandatorily directed to reach a conscious, reasoned decision to ensure fairness and transparency for candidates in public service.

Headnote:(A) Constitution of India - Article 14 - Service Law - Appointment - Eligibility criteria - Equivalence of educational qualifications - Scope of judicial review in matters of administrative decision-making regarding professional degree parity.

(B) Writ of Mandamus - Public authority's failure to address representations - Inaction by specialized committee - Obligation to provide a reasoned and conscious decision on matters affecting the status and employment of public servants.

Facts of the case:
Candidates applied for teaching positions, having specialized pedagogical qualifications. Despite meeting the recruitment stage, discrepancies regarding the equivalence of their specialized degree with standard teaching degrees were raised. Previous legal proceedings established that although the authorities had formed an expert committee to address such equivalency, no decisive action was taken on the representations submitted by the candidates for several years, leading to uncertainty regarding their continued employment.

Findings of Court:
The court noted that while the initial eligibility criteria were clear, the authorities failed to perform the administrative act of deciding on the equivalence of qualifications through the designated specialized committee, despite numerous directions and pending representations. This inaction, coupled with contradictory administrative orders, warranted judicial intervention to compel a final, reasoned decision.

Issues: Whether the authorities are obligated to decide on the equivalence of specialized educational degrees with regular degrees when such a committee was established for that specific purpose, and whether the failure to do so constitutes arbitrary administrative conduct.

Ratio Decidendi: Public bodies must act in a transparent and timely manner when authorized to determine matters of professional equivalence. When a committee is constituted to address technical parity, administrative inaction to reach a conscious, reasoned decision on representations impacts the livelihood of individuals and necessitates a judicial mandate to ensure due process and fairness.

Result: Writ petition allowed with a mandate to the committee to render a conscious decision on the representations.

Judgment & Order

HON’BLE MR. JUSTICE BISWAJIT PALIT

Heard Learned Counsel, Mr. A. Bhaumik appearing on behalf of the petitioners and also heard Learned Additional G.A., Mr. K. De appearing on behalf of the respondents.

02. This writ petition is filed by the petitioners seeking the following reliefs:

(a) Issue notice upon the Respondents;

(b) call for the records;

(c) Issue Rule calling upon the Respondents to show cause as to why the Respondents shall not be directed to reconstitute equivalence committee for the purpose of selection processes conducted vide Advertisement dated 09.09.2016 and 27.05.2017 for the post of Post Graduate Teacher and Graduate Teacher.

AND

Issue Rule calling upon the Respondents to show cause as to why a writ of mandamus or any other appropriate writ shall be not issued directing the Equivalence Committee to take a decision on granting ex-post facto equivalence to B.Ed Special Degree with B.Ed Regular Degree for the purpose of selection processes conducted vide Advertisement dated 09.09.2016 and 27.05.2017 for the post of Post Graduate Teacher and Graduate Teacher independent of what has been held by the Hon’ble High Court in the judgment and order dated 19.12.2018 passed in W.P.(C) No.1138/2016 title Smt. Sudipa Saha vs. The State of Tripura and Ors as per the order dated 21.05.2016 passed in Review Petition No.23/2019 based on materials already submitted by the petitioners regarding equivalence of B.Ed special with B.Ed Regular.

(iv) And after hearing the parties be pleased to make the rule absolute.

AND

In the interim, be pleased to restrain the Respondents from taking any coercive action against the Petitioners till disposal of the connected writ petition.

AND/OR

Pass any other order/orders may deemed fit and proper.

03. At the time of hearing, Learned Counsel for the petitioners drawn the attention of the Court that against an advertisement for the post of post-graduate teachers (STPGT) issued by TRBT (Annexure-1) and against another notification dated 27.05.2017 (Annexure-2) issued by TRBT, the petitioner Nos.1 to 5 applied for the post of post-graduate teachers and the rest petitioners applied for the post of graduate teachers and in those documents, the requisite qualifications were prescribed by the authority. The present petitioners applied for those posts and they were qualified in the written examination, but at the time of scrutiny of their documents their candidatures were not considered as the petitioners did not have/had valid B.Ed regular degree rather they have/had B.Ed Special degree which were not the eligible criteria for the posts which were advertised. Thereafter, all the petitioners who were being denied to issue appointment orders by the respondent-authority, filed separate writ petition before this Court and this Court by order dated 06.09.2017 passed an interim order. The operative portion of the said order runs as follows (Annexure-4):

“On comparative reading of Annexure-10-A and Annexure-10B to the writ petition, we are satisfied that the petitioner has made out a prima facie case. Consequently, as in our order dated 23.08.2017 passed in W.P.(C) No.1018/2017 any appointment made to the post of Graduate Teacher under the Education (School) Department, Government of Tripura shall be subject to the outcome of the writ petition.“

04. Thereafter, TRBT recommended the name of one of the petitioners, Smt. Sabita Barman for recruitment to the post of post-graduate teacher against the notification dated 07.04.2017 from STPGT 2016 (Annexure-5) and accordingly, said Sabita Barman was given appointment along with the other petitioners and they joined and continued their job accordingly. After that the respondent-State challenged the order of this High Court by filing appeal and the Division Bench of this High Court by judgment dated 19.12.2018 rejected the writ petition and vacated the interim order (Annexure-14).

Thereafter, one of the writ petitioners filed review petition before th

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