Delhi High Court

Administrative orders rejecting applications without considering submitted replies violate principles of natural justice and are unsustainable.

S S C Education College & Anr. vs National Council For Teacher Education & Anr.

Delhi High CourtJUDGMENT: June 29, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, an existing educational institution recognized for 4-year integrated courses since 2021, applied to the National Council for Teacher Education (NCTE) on October 4, 2025, to transition to the Integrated Teacher Education Programme (ITEP) course for the 2026-27 session.

Source reference: p.1-2

Following an inspection on February 16, 2026, the Western Regional Committee (WRC) issued a Show Cause Notice on April 1, 2026, under Sections 14 and 15 of the NCTE Act.

Source reference: p.2

Although the petitioners submitted a timely reply and requisite documents via the official portal, the WRC issued an order dated May 22, 2026, refusing the application without detailing the grounds for rejection other than stating the reply was "found deficient".

Source reference: p.2, 6

The petitioners challenged this refusal order via a writ petition under Article 226 of the Constitution.

Source reference: p.1
02

Issues

1. Whether the impugned refusal order dated May 22, 2026, was passed in violation of the principles of natural justice and statutory requirements under the NCTE Act?

Source reference: p.6

2. Whether the availability of an alternative remedy under Section 18 of the NCTE Act precludes the High Court from exercising its writ jurisdiction in this matter?

Source reference: p.2-3
03

Law Applied

The Court primarily calculated the application of Sections 14 and 15(3)(b) of the National Council for Teacher Education Act, 1993, regarding the recognition and transition of teacher education courses.

Source reference: p.2

It applied the constitutional Principles of Natural Justice, which necessitate that a quasi-judicial body must consider replies to show cause notices and pass reasoned/speaking orders.

Source reference: p.6

The Court relied on the procedural precedent set in Shri Jagat Narayan College & Anr. v. NCTE [W.P.(C) 7398/2026], where similar mechanical rejections were scrutinized.

Source reference: p.2
04

Reasoning

The Court observed that the WRC failed to provide the petitioners with a copy of the inspection report before issuing the Show Cause Notice.

Source reference: p.2

Upon reviewing the impugned order, the Court found it lacked substantive reasoning; specifically, Paragraph 6 merely stated the reply was "found deficient" without explaining how or why the documents were inadequate.

Source reference: p.5-6

The Court reasoned that once a reply is submitted within the stipulated time, the WRC is legally "incumbent" to consider the specific documents and explanations provided.

Source reference: p.6

By failing to engage with the petitioners' submissions, the WRC acted "mechanically," rendering the decision-making process flawed and in violation of natural justice.

Source reference: p.6

Consequently, even though an alternative remedy existed under Section 18, the procedural illegality warranted judicial intervention.

Source reference: p.2-6
05

Holding

The Court answered the issues in the affirmative, holding that the refusal order was illegal due to a lack of reasoning and failure to consider the petitioners' reply.

The High Court quashed the impugned order dated May 22, 2026, and remanded the matter to the WRC for reconsideration.

Source reference: p.6

The WRC was directed to: (i) provide the inspection report to the petitioners; (ii) allow the petitioners to submit further clarifications if required; and (iii) pass a fresh "reasoned and speaking order" within a total timeline of approximately four weeks.

Source reference: p.6

The petition was disposed of accordingly.

Source reference: p.6
Delhi High Court

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S S C Education College & Anr.vsNational Council For Teacher Education & Anr.

Delhi High Court · June 29, 2026

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