Subsequent acquisition of the prescribed teacher-training qualification entitles a TET candidate to certification.

The petitioner was pursuing a D.El.Ed. course for the academic session 2023–2025 and had completed Parts I and II of the course, while awaiting the final result when he applied for and appeared in T-TET 2024, Paper I.

The T-TET 2024 Prospectus provisionally permitted candidates pursuing D.El.Ed./B.Ed. to appear, subject to production of the final pass mark-sheet during scrutiny, failing which candidature could be cancelled.

The petitioner secured 88 marks in the T-TET examination but was not included in the final list of candidates qualified for issuance of TET certificates dated 13.12.2025.

During scrutiny, he was also asked to furnish an affidavit concerning an error in his father’s name in the caste certificate, which he submitted; no order expressly cancelling or rejecting his candidature was communicated.

During the pendency of the writ petition, the petitioner completed the D.El.Ed. course and obtained the requisite qualification.

He challenged the refusal to issue the T-TET certificate and the conditions in the Prospectus requiring production of the final professional-course mark-sheet.

The respondents contended that the petitioner had accepted the Prospectus conditions before appearing in the examination and that candidates without completed professional qualifications were not entitled to TET certificates.

Whether a candidate who was pursuing the prescribed D.El.Ed. course when appearing in T-TET, but subsequently acquired the qualification, could be denied issuance of the T-TET certificate solely for not possessing the final mark-sheet at the time of scrutiny.

Whether the respondent authority’s refusal to issue the T-TET certificate, despite the petitioner securing 88 marks and subsequently completing the D.El.Ed. course, violated Article 14 of the Constitution.

Whether the stipulations in the T-TET 2024 Prospectus requiring provisional candidates to produce the final D.El.Ed./B.Ed. pass mark-sheet were liable to be set aside or otherwise disregarded in the petitioner’s case.

The Court applied the NCTE guidelines dated 11.02.2011, particularly Clause 5(ii), which permits persons pursuing recognised teacher-education courses to appear in the TET; Clause 9, under which candidates securing 60% or more are treated as having passed the TET; and Clause 14, requiring the appropriate Government to issue TET certificates to successful candidates.

The Court also considered the principle in Omkar Singh v. State of Uttar Pradesh, (2021) 14 SCC 486, concerning the eligibility and treatment of candidates appearing under applicable qualification-related notifications.

It further applied Article 14 of the Constitution, holding that similarly situated eligible candidates must not be treated discriminatorily.

The petitioner also relied on State of Uttar Pradesh v. Arbind Kumar Srivastava, (2015) 1 SCC 347, which recognises that similarly situated persons should ordinarily receive equal relief.

The Court found it undisputed that the petitioner was pursuing the D.El.Ed. course when he appeared in the TET and that he subsequently completed the course and obtained the qualification.

Although the Prospectus required provisional candidates to produce the final pass mark-sheet during scrutiny, the respondents could not identify any material establishing that a candidate permitted to appear while pursuing the prescribed course became permanently ineligible for a TET certificate merely because the qualification was completed after the examination.

The petitioner had also secured 88 marks, exceeding the 60% threshold contemplated by the NCTE guidelines.

The respondents’ reliance on the earlier litigation in WP(C) No.379 of 2025 and the related intra-court appeal did not justify denial of relief, particularly because the present factual circumstances included the petitioner’s subsequent completion of the D.El.Ed. course.

In these circumstances, refusal to issue the certificate to the otherwise qualified petitioner was held to be discriminatory and contrary to Article 14.

The Court held that the petitioner was entitled to consideration for issuance of the T-TET certificate after subsequently acquiring the prescribed D.El.Ed. qualification.

The TRBT was directed to issue the T-TET certificate within three months, after giving the petitioner an opportunity to produce the final D.El.Ed. mark-sheet, provided he fulfilled all other prescribed criteria.

Pending applications, if any, were disposed of accordingly.