Facts
The petitioners, recognized since 2007 to conduct a 4-year integrated B.A.B.Ed. course, applied for transition to the Integrated Teacher Education Programme (ITEP) for the 2026-27 academic session following NCTE public notices.
Source reference: p.1, para. 2An inspection was conducted on May 6, 2026.
Source reference: p.2, para. 2The Western Regional Committee (WRC) subsequently issued a Final Show Cause Notice on May 14, 2026, which allegedly omitted specific grounds for deficiency and was issued without providing the inspection report.
Source reference: p.2, para. 3Despite the petitioners’ reply and document submission, the WRC issued an order on June 12, 2026, refusing the application.
Source reference: p.2, paras. 4-5The petitioners challenged this order before the High Court on grounds of non-reasoning and violation of natural justice.
Source reference: p.2, para. 6Issues
Whether the impugned order dated June 12, 2026, passed by the WRC, was a reasoned order or if it was passed mechanically in violation of the principles of natural justice.
Source reference: p.6, paras. 11-12Whether the failure to provide the inspection report and specific grounds of deficiency in the Show Cause Notice vitiates the decision-making process.
Source reference: p.2, para. 3; p.6, para. 14Law Applied
Principles of Natural Justice, specifically the requirement for a quasi-judicial authority to pass a "reasoned and speaking order" after considering the representations and documents submitted by an applicant.
Source reference: p.6, paras. 11-12; p.6, para. 15Section 18 of the NCTE Act regarding the alternative remedy of appeal.
Source reference: p.2, para. 8Shri Jagat Narayan College & Anr. v. NCTE & Anr. [W.P.(C) 7398/2026] regarding similar procedural lapses by the respondent.
Source reference: p.2, para. 6Reasoning
The WRC’s impugned order was devoid of any substantive reasoning.
Source reference: p.6, para. 11Aside from a generic statement in paragraph 6 of the order claiming that the reply was "found deficient," the WRC failed to specify the nature of the deficiencies or explain why the petitioners' documentation was inadequate.
Source reference: p.6, para. 11When an institute submits a reply to a Show Cause Notice, the WRC is under a legal obligation to actively consider the specific content of that reply and the attached documents.
Source reference: p.6, para. 11By failing to do so, the WRC acted mechanically and breached the principles of natural justice, rendering the order legally unsustainable.
Source reference: p.6, para. 12The Court noted the procedural unfairness in withholding the inspection report from the petitioners.
Source reference: p.6, para. 14Holding
The Court quashed the order dated June 12, 2026, declaring it illegal and passed in violation of natural justice.
The matter was remanded to the WRC for reconsideration of the petitioners’ reply to the Show Cause Notice within two weeks; the WRC must finally pass a "reasoned and speaking order" after evaluating the full record.
Source reference: p.6, paras. 14-15The writ petition was disposed of accordingly.
Source reference: p.7, para. 16Original Court PDF
Shri Jivan Jyoti Trust & Anr.vsNational Council For Teacher Education & Anr.
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in