Subsequent regulatory changes rendered the recognition claim infructuous, requiring return of deposited FDRs.

The petitioner-college applied online on 30 June 2016 for recognition to conduct the B.Ed. course; the application was received by the Eastern Regional Committee (“ERC”) of the NCTE on 8 July 2016.

The ERC initially refused recognition on 13 November 2017, citing absence of a No Objection Certificate, non-depiction of the multipurpose hall in the building plan, and non-submission of the building completion certificate.

On appeal, the matter was remanded on 16 May 2018. Thereafter, the ERC issued a Letter of Intent on 31 October 2018 under Regulation 7(13) of the NCTE Regulations, 2014, requiring, inter alia, compliance regarding faculty qualifications and furnishing of fixed deposits of ₹5 lakh towards the Endowment Fund and ₹7 lakh towards the Reserve Fund.

The petitioner allegedly failed to comply within the extended period granted by the ERC, and recognition was ultimately refused by order dated 1 March 2019 following a show-cause notice.

The petitioner’s appeal was rejected by the NCTE Member Secretary on 5 July 2019.

Whether the petitioner was entitled to recognition for the B.Ed. programme on the basis of its 2016 application, the alleged delay in processing, the Letter of Intent, and its claimed compliance with the applicable requirements?

Whether the subsequent changes in the regulatory framework pursuant to NEP 2020 rendered adjudication of the petitioner’s original claim for recognition ineffective or infructuous?

Whether the NCTE could retain the FDRs of ₹5 lakh and ₹7 lakh furnished pursuant to the Letter of Intent after the original recognition proceedings had lost practical efficacy?

Whether the petitioner should be permitted to submit a fresh application under the regulatory framework prevailing on the date of such application?

The Court considered Regulation 5(1) of the NCTE (Recognition Norms and Procedure) Regulations, 2014, concerning the manner and time for submitting an application, and Regulation 7(6), prescribing the processing timeline and communication of the decision on recognition applications.

Regulation 7(13) governed the issuance of the Letter of Intent and the subsequent compliance requirements.

Section 15(3)(b) of the National Council for Teacher Education Act was invoked in relation to the show-cause process preceding refusal of recognition.

The Court also considered the principle of time-bound processing recognised in Maa Vaishno Devi Mahila Mahavidyalaya v. State of U.P., (2013) 2 SCC 617.

However, the Court applied the doctrine that a court need not adjudicate a dispute where intervening events have rendered the relief ineffective or the controversy has substantially lost its practical significance.

It further held that requirements arising at the post-application or Letter-of-Intent stage could not, in the circumstances, be treated as an initial defect or incompleteness in the application so as to justify retention of the FDRs.

The Court noted that the regulatory regime governing teacher education had materially changed after the petitioner’s 2016 application, particularly following NEP 2020 and the NCTE’s move towards multidisciplinary institutions and integrated teacher-education programmes.

Consequently, even if the Court examined the petitioner’s allegations regarding delayed processing, the Letter of Intent, or non-compliance with the earlier framework, a favourable determination could not realistically result in recognition under a regulatory regime that had since changed substantially.

The Court therefore declined to undertake an adjudication of the original recognition dispute.

In contrast, the claim for return of the FDRs remained capable of effective adjudication.

The FDRs were furnished only pursuant to subsequent requirements arising during processing and after issuance of the Letter of Intent, rather than being documents whose absence rendered the original application incomplete.

Once the original proceedings could no longer yield recognition under the earlier framework, continued retention of the FDRs was held unjustified.

It directed the concerned NCTE authority to return or release the FDRs/amounts of ₹5 lakh and ₹7 lakh furnished towards the Endowment Fund and Reserve Fund, respectively, within eight weeks from receipt or production of the order.

The petitioner was granted liberty to submit a fresh application for recognition, subject to compliance with all rules, regulations, notifications, norms and criteria applicable on the date of the fresh application.

The writ petition was accordingly disposed of.