CAT - ['Delhi']

Degrees from UGC-recognized universities are valid for teaching appointments without separate NCTE recognition.

ARVIND vs DSSSB

CAT - ['Delhi']JUDGMENT: April 21, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a candidate for the post of TGT (Social Science) (Post Code 39/21), challenged the respondents' refusal to accept his B.Ed. degree obtained from Singhania University for appointment

Source reference: p. 2, para. 1

The applicant contended that his qualification is valid as the university is established under a State Act and recognized by the UGC

Source reference: p. 4, para. 5

The respondents argued that the degree was invalid for appointment because Singhania University lacked specific recognition from the National Council for Teacher Education (NCTE) as mandated by the NCTE Act, 1993

Source reference: p. 5, para. 9-10

The matter falls under the shadow of a similar dispute involving the same university currently pending before the Delhi High Court

Source reference: p. 12, para. 4
02

Issues

1. Whether a B.Ed. degree obtained from a UGC-recognized statutory university (Singhania University) is valid for teacher recruitment even if the university lacks specific NCTE recognition

Source reference: p. 2, para. 1; p. 7, para. 12

2. Whether the present matter is squarely covered by the precedent in Ajay Dagar v. GNCTD & Ors. (OA No. 1386/2021)

Source reference: p. 2, para. 2
03

Law Applied

Section 14 of the National Council for Teacher Education (NCTE) Act, 1993, which requires "institutions" to seek recognition for teacher education

Source reference: p. 5, para. 12

"University" is separately defined under Section 2(n) of the Act

Source reference: p. 8, para. 9

The Supreme Court precedent in Bharathidasan University v. AICTE established that statutory universities are not subordinate to regulatory bodies like AICTE/NCTE for internal academic programs unless the parent statute expressly mandates prior approval

Source reference: p. 4, para. 8; p. 11, para. 19

The Punjab and Haryana High Court decision in Tara Rani v. State of Punjab (LPA No. 1167/2018) held that statutory universities need not take NCTE recognition for teacher training courses

Source reference: p. 8, para. 15
04

Reasoning

The Tribunal observed that the applicant's case is identical to Ajay Dagar v. GNCTD, where the Tribunal previously ruled that Section 14 of the NCTE Act mandates recognition for "institutions," a category that does not automatically merge with "Universities" established by legislative enactment

Source reference: p. 9, para. 9; p. 12, para. 2

The court reasoned that since Singhania University is a statutory body under the UGC Act, it possesses an inherent right to confer degrees

Source reference: p. 4, para. 5

While the respondents pointed to the 2014 NCTE Regulations including universities within its ambit, the Tribunal noted that delegated legislation cannot expand the scope of the parent Act

Source reference: p. 11, para. 18

Following the ratio in Bharathidasan University, the Tribunal found the respondents' rejection arbitrary, as regulatory bodies cannot impose extra-statutory requirements on universities

Source reference: p. 11, para. 19
05

Holding

The Tribunal allowed the O.A. and quashed the refusal to recognize the applicant's degree.

The Tribunal mandated that these directions are subject to the final outcome of the pending proceedings in W.P.(C) No. 3821/2026 before the Hon’ble Delhi High Court.

Source reference: p. 13, para. 5

The matter is squarely covered by Ajay Dagar and directed the respondents to consider the applicant’s candidature for the TGT post and issue an appointment letter if he is otherwise meritorious, with notional benefits granted upon appointment.

Source reference: p. 13, para. 5; p. 12, para. 21
CAT - ['Delhi']

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ARVINDvsDSSSB

CAT - ['Delhi'] · April 21, 2026

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