Facts
Petitioner No. 1 operates Kamalnath College, which had NCTE recognition for its B.P.Ed. course and University affiliation.
Source reference: para. 2–5Following an inspection on 17–18 July 2026, the NCTE issued a show-cause notice dated 27 July 2026 alleging deficiencies.
Source reference: para. 2–5The petitioners challenged the inspection and notice, contending that they had inadequate prior notice, were not supplied the inspection report, and that their response and corrective measures had not been considered.
Source reference: para. 2–5They also challenged the College’s removal from the counselling portal.
Source reference: para. 2–5The NCTE stated that it considered the petitioners’ reply and issued a further, final show-cause notice on 25 September 2026, leaving the statutory proceedings pending.
Source reference: para. 2–5, 8, 13–14The High Court dismissed the petition.
Source reference: para. 2–5, 8, 13–14Issues
1. Whether the High Court should interfere under Article 226 with the NCTE show-cause proceedings before the competent authority had made a final decision.
Source reference: para. 8, 11, 132. Whether the College’s removal from the counselling portal warranted relief in this petition.
Source reference: para. 10Law Applied
Under Sections 12 and 17 of the National Council for Teacher Education Act, 1993, the NCTE is empowered to maintain standards in teacher education, monitor compliance, and initiate proceedings where a recognised institution is alleged to have breached statutory requirements or recognition conditions.
Source reference: para. 8, 11, 13A show-cause notice ordinarily does not warrant judicial interference before the authority reaches a final decision; interference may be justified in exceptional cases, such as where the notice is wholly without jurisdiction or otherwise illegal.
Source reference: para. 8, 11, 13The Court relied on Union of India v. Kunisetty Satyanarayana, (2006) 12 SCC 28, and State of Jharkhand v. Rukma Kesh Mishra, 2025 INSC 412.
Source reference: para. 8, 11, 13Reasoning
The Court treated the NCTE proceedings as ongoing: the petitioners’ reply had been considered, and a further show-cause notice had afforded them another opportunity to present their case.
Source reference: para. 9–13The alleged deficiencies—including concerns about facilities and the institutions’ premises—were matters for the competent statutory authority to assess on the record and through physical verification, not for the High Court to determine as an appellate forum.
Source reference: para. 9–13The Court found no basis to intervene at the show-cause stage under the principles governing Article 226 review.
Source reference: para. 9–13It also noted that Respondent No. 5, the University, did not control the counselling portal; it was operated by the State Department of Higher Education.
Source reference: para. 9–13Holding
The Court dismissed the writ petition, declining to quash the show-cause proceedings or grant relief concerning the counselling portal.
It made no order as to costs.
Source reference: para. 10, 14Acts & Sections Cited
4 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.
National Council for Teacher Education Act, 19934
Original Court PDF
Arera Education SocietyvsThe State Of Madhya Pradesh
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Original judgment, available to read, download and summarize on LawLens.in
