Candidates meeting advertised qualifications with timely RCI renewal must be recommended for appointment.

The petitioner, a Scheduled Caste candidate, applied for the post of Special Educator under the recruitment notification dated 10 February 2025.

He held a B.Ed. in Special Education from NEHU, completed in the 2014–2016 academic session, and had obtained 33.57% in an earlier bachelor’s degree. He later obtained another bachelor’s degree with 68.80% marks.

The recruitment notice required 50% marks in either graduation or post-graduation, a B.Ed. in Special Education from an RCI-recognized institution, and RCI registration; it allowed up to 5% relaxation for SC/ST/PH candidates.

The petitioner applied before the 17 March 2025 deadline, sat the selection test, and scored 89 out of 150. At document verification, his candidature was rejected on the grounds that he lacked the required marks and had not produced a valid RCI registration certificate by the application deadline.

He challenged that rejection by writ petition.

1. Whether the petitioner met the advertised minimum academic qualification, considering his later bachelor’s degree with 68.80% marks, despite his earlier degree result of 33.57%.

2. Whether the petitioner satisfied the RCI-registration requirement by the application deadline, given that he had applied to renew his registration before its expiry and the renewed certificate was issued later.

3. Whether the respondents could rely on NCTE requirements or the RCI regulations of 2015 to disqualify the petitioner when those requirements were not stated in the recruitment notice or were inapplicable to his course session.

The recruitment notice governed eligibility: candidates were required to have at least 50% marks in either graduation or post-graduation, a B.Ed. in Special Education or equivalent from an RCI-recognized institution, and RCI registration; up to 5% relaxation applied to SC/ST/PH candidates.

The respondents invoked NCTE regulations and RCI norms, including the RCI regulations published on 15 May 2015. The Court treated the 2015 norms as inapplicable to the petitioner’s 2014–2016 course session, noting that the revised norms applied from the 2016–2017 academic session.

Sections 19 and 21 of the Rehabilitation Council of India Act, 1992, were referred to by the petitioner; the judgment did not set out a separate statutory test under those provisions.

No judicial precedent was relied upon.

The Court read the advertised academic requirement as permitting the required marks to be obtained in either graduation or post-graduation, and noted that the petitioner’s later bachelor’s degree carried 68.80% marks.

It found that the respondents had not disputed that result and could not substitute additional NCTE requirements that were absent from the recruitment notice.

The Court also concluded that the 2015 RCI norms did not govern the petitioner’s earlier course session.

On registration, the petitioner’s original RCI registration had been issued in 2020 and he had applied for renewal on 21 February 2025, before expiry; the later-issued certificate recorded validity through 28 June 2030.

The Court therefore rejected the respondents’ contention that the later issuance date meant the petitioner lacked valid registration at the application stage.

It further observed that the respondents’ positions were contradictory and did not adequately address the petitioner’s later degree or registration evidence.

It directed them to recommend his name for appointment as a Special Educator against an SC post under the Directorate of Secondary Education, Government of Tripura, within three months of the judgment.