Simultaneous pursuit of regular and distance degrees prior to 2022 guidelines is valid if compliant with university norms.

In brief

The question

1. Whether the simultaneous pursuit of two academic degrees (one through regular mode and another through distance/Open and Distance Learning mode) prior to the 2022 UGC Guidelines is legally valid for the purpose of public employment

The court held

The court held that the revised UGC policy, which treats simultaneous degrees pursued before 2022 as valid, must be the governing standard for determining eligibility

It also directed

The Court disposed of the petition by directing Respondent No. 1 to reconsider the validity of the Petitioners' qualifications in light of the clarified and modified UGC Guidelines and pass a reasoned speaking order within six weeks; if favorable, Petitioners are to be appointed with notional pay fixation and seniority based on original selection merit without arrears

01Facts

The four Petitioners were successful candidates in the Eklavya Model Residential Schools (EMRS) Recruitment 2023 for the posts of Post Graduate Teachers (PGT) in Hindi, English, and Economics

¶ 5-6

After document verification and the issuance of provisional appointment letters, Respondent No. 1 cancelled their candidatures via emails dated June 19, 2024

¶ 6

The cancellation was based on the ground that the Petitioners had pursued two degrees—a Master of Arts (M.A.) and a Bachelor of Education (B.Ed.)—simultaneously, which the Respondent deemed impermissible under existing norms

¶ 6

The Petitioners challenged this, citing various University Grants Commission (UGC) communications suggesting that simultaneous degrees (one regular, one distance) were permissible

¶ 7-11

02Issues

i.1. Whether the simultaneous pursuit of two academic degrees (one through regular mode and another through distance/Open and Distance Learning mode) prior to the 2022 UGC Guidelines is legally valid for the purpose of public employment

¶ 11, 21

ii.2. Whether the Respondent’s cancellation of the Petitioners' candidatures was arbitrary and in violation of Article 14 of the Constitution

¶ 5, 11

03Law Applied

University Grants Commission (UGC) Act, 1956, which empowers the UGC to maintain standards of teaching and examination

¶ 23

UGC Guidelines for Pursuing Two Academic Programmes Simultaneously (2022), specifically the retrospective clarification approved in the 589th meeting of the Commission (April 3, 2025)

¶ 22-23

Procedural fairness in administrative action is essential for accurate outcomes, referencing Dharampal Satyapal Ltd. v. Deputy Commissioner of Central Excise

¶ 13

Provisions in the judgment · 1 · Linked ones open on LawLens

Right to Information Act, 2005 Section 6

04Reasoning

The court examined the evolving stance of the UGC regarding simultaneous degrees and found that the 589th meeting held on April 3, 2025, modified the 2022 Guidelines to grant retrospective validity to simultaneous degrees obtained before 2022, provided they met individual university and statutory council norms

¶ 23-24

The court found that since the UGC—the apex statutory body for educational standards—now recognizes such simultaneous degrees as valid, the Respondent's primary reason for canceling the candidatures (non-recognition of dual degrees) was potentially meritless under the updated regulatory framework

¶ 25-26

05Holding

The court held that the revised UGC policy, which treats simultaneous degrees pursued before 2022 as valid, must be the governing standard for determining eligibility

¶ 25

¶ 26-28

LawLens.Delhi High Court

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