Madras High Court
Education LawAdministrative and Public Law

Tamil Nadu school rules on correspondent appointments cannot override minority institutions’ autonomy, Madras High Court rules

B.David Anbu Prabaharan, vs The Director of School Educa

Madras High CourtJUDGMENT: September 29, 20262 MIN READSOURCE JUDGMENT
Tamil Nadu school rules on correspondent appointments cannot override minority institutions’ autonomy, Madras High Court rules. B.David Anbu Prabaharan, vs The Director of School Educa. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellant stated that he had been appointed Pastorate Chairman of Keela Sadayamangulam Pastorate and, in that capacity, Correspondent of three TDTA schools for a three-year term; his appointment as Correspondent had been approved by the District Educational Officer on 27 July 2023.

Source reference: p.3

After the fifth respondent directed another person to take charge of the Pastorate, a consequential order appointed that person as Correspondent of the schools.

Source reference: p.3

The appellant sought certiorari to quash the orders dated 21 February 2026.

Source reference: p.2

The Single Judge dismissed the writ petition, holding that Rule 25(2) of the Tamil Nadu Private Schools (Regulation) Rules, 2023 could not be enforced against minority institutions and that the dispute was internal to the educational agency; the appellant was given liberty to approach the Civil Court.

Source reference: p.4

The appellant challenged that decision in this writ appeal.

Source reference: p.4
02

Issues

1. Whether Rule 25(2) of the Tamil Nadu Private Schools (Regulation) Rules, 2023 could be applied to the schools, which the Court found to be minority institutions.

Source reference: p.5

2. Whether the Single Judge’s dismissal of the writ petition on the ground that the dispute was internal to the educational agency and did not warrant writ-court interference was infirm.

Source reference: pp.4–5
03

Law Applied

The Court applied Rule 25(2) of the Tamil Nadu Private Schools (Regulation) Rules, 2023, holding that it could not be applied to minority institutions.

Source reference: p.5

It also relied on the principle that minority institutions are protected from the asserted interference in their administration.

Source reference: p.5

No statutory provision or precedent was expressly identified in the appellate judgment as the basis for that principle.

Source reference: no citation
04

Reasoning

The Court accepted that the schools involved were minority institutions and concluded that Rule 25(2) could not be used to challenge the changes in their administration.

Source reference: p.5

It found no infirmity in the Single Judge’s conclusion that the removal of a Pastorate Chairman was not a discharge of public duty and that the dispute was internal to the educational agency.

Source reference: pp.4–5

The Court also referred to its judgment in the connected appeals, which affirmed the Church of South India’s administrative control over the Tirunelveli Diocese and noted that the Church’s Constitution and diocesan rules bound members by faith and agreement.

Source reference: p.4
05

Holding

The Court held that the Single Judge correctly concluded that Rule 25(2) did not apply to the minority institutions and found no reason to interfere.

The writ appeal was dismissed, with no order as to costs, and the connected miscellaneous petition was closed.

Source reference: p.5
Madras High Court

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B.David Anbu Prabaharan,vsThe Director of School Educa

Madras High Court · September 29, 2026

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