Tripura High Court orders T-TET certificate and teacher recruitment consideration for NIOS-trained candidate with 18-month D.El.Ed. course

The petitioner completed an 18-month Diploma in Elementary Education (D.El.Ed.) through the National Institute of Open Schooling (NIOS) in Open and Distance Learning mode and applied for T-TET 2024, Paper-I. Although he qualified in the examination, his candidature was not processed for document verification on the ground that he did not possess the requisite two-year D.El.Ed. qualification.

The respondents contended that the petitioner was absent from the document-verification process held on 23 July 2025 and, under the Prospectus-cum-Instruction, his candidature therefore stood cancelled.

The petitioner asserted that he and similarly situated candidates were not permitted to enter the verification premises because they possessed the 18-month NIOS D.El.Ed. qualification.

Relying on earlier decisions of the High Court, particularly in WP(C) No. 27 of 2026, WP(C) No. 603 of 2025 and connected matters, he sought document verification, issuance of the T-TET certificate, and consideration for appointment as Under-Graduate Teacher pursuant to the advertisement dated 21 February 2026.

1. Whether the petitioner’s 18-month D.El.Ed. qualification obtained through NIOS in ODL mode, completed within the prescribed period, could be treated as a valid qualification for T-TET 2024, Paper-I?

2. Whether the petitioner could be denied document verification and treated as disqualified merely because he was recorded as absent from the scheduled verification process?

3. Whether the petitioner was entitled to issuance of the T-TET Paper-I certificate and consideration/recommendation for appointment as Under-Graduate Teacher, subject to verification of his past service?

The Court relied on the legal position that the 18-month NIOS D.El.Ed. programme was introduced pursuant to the extension of the statutory period under Section 23(2) of the Right of Children to Free and Compulsory Education Act, 2009, permitting in-service untrained elementary teachers to acquire the minimum qualification by 31 March 2019.

It relied on the NCTE’s recognition of the NIOS D.El.Ed. course through its order dated 22 September 2017 and the corresponding approval and communications of the Government of India, which treated the course as a valid training programme for eligible in-service teachers.

The Court followed the principles laid down in the Supreme Court judgment referred to as Viswanath, particularly that persons who were in service as on 10 August 2017 and completed the recognised 18-month diploma were to be treated as valid diploma holders for applying to other institutions and for promotional or recruitment purposes.

It also followed the High Court’s earlier decisions, including WP(C) No. 27 of 2026, which had attained finality and directed recognition of the 18-month qualification, issuance of TET certificates, and participation in the recruitment process, subject to verification of past service.

The Court treated the petitioner’s case as covered by its earlier decisions recognising the 18-month NIOS D.El.Ed. qualification for eligible in-service teachers.

The respondents’ reliance on the petitioner’s absence from the verification attendance sheet and the cancellation clause in the prospectus could not defeat his claim where the alleged absence was asserted to have resulted from the authority’s refusal to permit candidates with the 18-month qualification to participate in verification.

Since the earlier judgments had recognised the qualification and had not been challenged, the Court held that the respondents could not adopt an inconsistent position or reject the petitioner solely on the basis that he lacked a two-year D.El.Ed. qualification.

Nevertheless, the Court made the relief conditional upon verification that the petitioner was in service on 10 August 2017 in a government, government-aided, or unaided private school, consistent with the eligibility basis recognised in the earlier judgments.

The respondents were directed to arrange the petitioner’s document verification within one month from the date of judgment, issue the T-TET Paper-I 2024 certificate subject to verification of his past service, and recommend his name to the Government for appointment to the post for which he had applied within the subsequent three months.

Thus, the Court accepted that the petitioner’s 18-month NIOS D.El.Ed. qualification could not, by itself, be treated as invalid, while making issuance of the certificate and recruitment recommendation subject to verification of the petitioner’s qualifying past service.