Gauhati High Court

Distance education degrees from "off-campus" study centres lacking UGC approval are invalid for provincialization of service.

Babul Hossain, vs Rezzaqul Hussain And 6 Ors

Gauhati High CourtJUDGMENT: May 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner was appointed as a Library Assistant at Janapriya College in 2006

Source reference: p. 6

In 2010, the college allegedly appointed him as an Assistant Librarian

Source reference: p. 8

When the State provincialized services under the Act of 2018, the private respondent (Respondent No. 7), originally a Junior Assistant, was provincialized in the post of Library Assistant

Source reference: p. 8

Petitioner’s claim for provincialization as Assistant Librarian was rejected via a speaking order dated 28.08.2023 because his BLISC degree was obtained via off-campus distance mode from Vinayaka Missions University, which was deemed invalid

Source reference: p. 14

The petitioner challenged this rejection and the appointment of Respondent No. 7, alleging record manipulation and seniority

Source reference: p. 7
02

Issues

1. Whether the speaking order dated 28.08.2023, rejecting the petitioner’s claim, is illegal or arbitrary?

Source reference: p. 13

2. Whether the appointment of the petitioner as Assistant Librarian was a result of record manipulation, and if he should be considered for the post of Library Assistant?

Source reference: p. 13

3. Whether the provincialization of Respondent No. 7 as Library Assistant is illegal for lack of requisite qualification or seniority?

Source reference: p. 13
03

Law Applied

The court applied the Assam Education (Provincialisation of Services of Non-Teaching Staff of Venture Educational Institutions) Act, 2018, specifically Section 4, which mandates minimum qualifications and six years of continuous service

Source reference: p. 22

It relied on UGC Regulations regarding the invalidity of degrees obtained from off-campus study centers of State/Deemed Universities outside their territorial jurisdiction, as affirmed in Purnendu Sekhar Debnath v. State of Assam

Source reference: p. 16-17

The court applied the principle from Commissioner of Police v. Raj Kumar regarding the employer's latitude in determining "suitability"

Source reference: p. 24

The court applied the principle from State of Orissa v. Dr. (Miss) Binapani Dei regarding the court's discretion to decline inquiries into complicated disputed questions of fact under Article 226

Source reference: p. 20
04

Reasoning

The court found that the petitioner’s BLISC degree was non-est in law because it was obtained through an off-campus center without requisite UGC/Distance Education Bureau approval

Source reference: p. 17

Regarding the petitioner's claim that he never resigned as Library Assistant and that records showing him as Assistant Librarian were manipulated, the court noted that the petitioner himself had signed information sheets claiming the post of Assistant Librarian to seek higher provincialization benefits

Source reference: p. 21

The court declined to conduct a roving inquiry into the "manipulation" of college records, characterising it as a disputed fact requiring evidence beyond the writ jurisdiction's scope

Source reference: p. 20

Regarding Respondent No. 7, the court accepted the State's position that Junior Assistant and Library Assistant posts are of the same rank/category and that Respondent No. 7 held the requisite seniority from 2006

Source reference: p. 21-23
05

Holding

The court dismissed the writ petition, holding that the speaking order was valid and the petitioner lacked the necessary valid qualifications for provincialization

The court further allowed I.A.(Civil) No. 85/2024, vacating the interim stay on the provincialization of Respondent No. 7; the employer (State) acted within its legal latitude in selecting the senior-most eligible candidate for the available post

Source reference: p. 24-25
Gauhati High Court

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Babul Hossain,vsRezzaqul Hussain And 6 Ors

Gauhati High Court · May 25, 2026

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