18-Month NIOS D.El.Ed. Diploma Is Valid for TET Certification and Recruitment of In-Service Teachers

In brief

The question

1. Whether the 18-month D.El.Ed diploma conducted through NIOS is a valid professional qualification for the issuance of TET certificates and subsequent employment

The court held

The High Court allowed the writ petition, holding that the 18-month D.El.Ed is a valid qualification for the petitioners

It also directed

The Court directed the respondent authority to issue TET certificates to the petitioners within six weeks

The petitioners were permitted to participate in the recruitment process initiated by the notification dated February 21, 2026, subject to the respondents verifying that each petitioner was indeed in employment as of August 10, 2017

01Facts

The 16 petitioners completed an 18-month Diploma in Elementary Education (D.El.Ed) through the National Institute of Open Schooling (NIOS) in ODL mode by March 31, 2019

p. 5

They applied for the Tripura Teachers’ Eligibility Test (T-TET) 2024 (Paper-I and II), appeared for the examination, and scored above the qualifying marks

p. 5

However, the Teachers Recruitment Board, Tripura (TRBT) refused to issue TET certificates, contending that an 18-month program was invalid as compared to the standard 2-year duration

pp. 5-6

The petitioners sought a writ of mandamus to recognize their diploma and compel the issuance of certificates

p. 4

02Issues

i.1. Whether the 18-month D.El.Ed diploma conducted through NIOS is a valid professional qualification for the issuance of TET certificates and subsequent employment

p. 4 / para. 03

ii.2. Whether the petitioners are entitled to the benefit of the "one-time measure" previously recognized by the High Court and Supreme Court for in-service untrained teachers

p. 6 / para. 05

03Law Applied

Section 23(2) of the Right of Children to Free and Compulsory Education (RTE) Act, which was amended by Parliament to extend the training deadline for untrained teachers to March 31, 2019

p. 8

The precedent set in Viswanath v. State of Tripura (Supreme Court, 10.12.2024), which held that the 18-month diploma is valid for persons in employment as of August 10, 2017

p. 7

High Court’s own coordinate bench decisions in WP(C) No. 242/2025 and WP(C) No. 243/2025, which mandated the inclusion of such candidates in selection lists

pp. 7-8

Provisions in the judgment · 1 · Linked ones open on LawLens

Right of Children to Free and Compulsory Education Act, 2009 Section 23

04Reasoning

The Court noted that the petitioners underwent the D.El.Ed course under a special arrangement by the MHRD and NCTE intended to qualify approximately 11 lakh in-service untrained teachers

p. 8

The NCTE’s recognition order dated September 22, 2017, specifically subsumed a 6-month internship period into the 18-month course to satisfy the 2-year requirement, acknowledging that these candidates were already teaching

p. 8

The Court reasoned that since the petitioners completed the course within the statutory window (ending March 31, 2019) and the TRBT had already allowed them to sit for the exam, the state could not now take a contradictory stand

p. 8

The Court emphasized that the TRBT is bound by the academic guidelines formulated by the NCTE as the sole academic authority

p. 8