Delhi High Court

Order passed mechanically without considering reply to show cause notice violates principles of natural justice.

Bansal College Of Higher Education & 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 established educational institution since 2017, applied to the National Council for Teacher Education (NCTE) on October 5, 2025, seeking to transition their existing 4-year integrated B.A.B.Ed/B.Sc.B.Ed course to the Integrated Teacher Education Programme (ITEP) course.

Source reference: p. 1-2

Following an inspection on April 30, 2026, the Western Regional Committee (WRC) issued a Show Cause Notice on May 13, 2026, under 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 on June 3, 2026, refusing the application.

Source reference: p. 2

The petitioners challenged this refusal on the grounds that their reply was not considered and the inspection report was never provided.

Source reference: p. 2
02

Issues

1. Whether the impugned refusal order dated June 3, 2026, was passed in violation of the principles of natural justice and without due consideration of the petitioners' reply.

Source reference: p. 6, para. 10

2. Whether the existence of an alternative remedy under Section 18 of the NCTE Act bars the High Court from exercising its writ jurisdiction under Article 226 in this instance.

Source reference: p. 2, para. 6
03

Law Applied

Principles of Natural Justice, which require administrative bodies to act fairly and consider representations before passing adverse orders.

Source reference: p. 6, para. 10

Sections 14 and 15(3)(b) of the National Council for Teacher Education Act, 1993, regarding the recognition of teacher education institutions.

Source reference: p. 2, para. 3

Section 18 concerning the statutory appeals process.

Source reference: p. 2, para. 6

Judicial precedent in Shri Jagat Narayan College & Anr. v. NCTE [W.P.(C) 7398/2026] regarding similar procedural lapses by the Council.

Source reference: p. 2, para. 5
04

Reasoning

The court found that while the WRC’s order claimed to have considered the petitioners' reply in Meeting No. 461, it failed to provide any specific reasons for finding the reply "deficient".

Source reference: p. 6, para. 9

The court observed that it was "incumbent upon the WRC" to meaningfully evaluate the submitted documents once a reply to the Show Cause Notice had been filed.

Source reference: p. 6, para. 9

By failing to address the substance of the petitioners' response, the court determined that the WRC had acted "mechanically" and in direct violation of the Principles of Natural Justice.

Source reference: p. 6, para. 10

Consequently, the lack of a reasoned order and the failure to provide the inspection report rendered the administrative action legally unsustainable regardless of the availability of an alternative remedy.

Source reference: p. 6, para. 10
05

Holding

The court quashed the impugned refusal order dated June 3, 2026, declaring it illegal.

The matter was remanded to the WRC with directions to: (i) provide the petitioners with a copy of the inspection report; (ii) reconsider the petitioners' reply to the Show Cause Notice within two weeks; and (iii) pass a reasoned and speaking order within one week thereafter.

Source reference: p. 6, para. 12-14

The writ petition was disposed of in these terms.

Source reference: p. 7, para. 15
Delhi High Court

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Bansal College Of Higher Education & Anr.vsNational Council For Teacher Education & Anr.

Delhi High Court · June 29, 2026

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