THE SECRETARY CUM MANAGER, MAJILIS ARTS AND SCIENCE COLLEGE V. NATIONAL COUNCIL FOR TEACHER EDUCATION & ANR 2025:KER:41303:

DATE: 11/06/2025

COURT: High Court of Kerala

BENCH: Justice D.K. Singh

FACTS:

The petitioner College is an autonomous minority institution recognized by the State Government and affiliated with the University of Calicut. Accredited with an ‘A’ grade by NAAC, the College offers 20 undergraduate and 7 postgraduate courses under a self-financing scheme. In line with the National Education Policy 2020, the National Council for Teacher Education (NCTE) introduced amended regulations published on 22.10.2021, transitioning to a four-year Integrated Teacher Education Programme (ITEP). A public notice dated 05.02.2024 invited applications for institutions recognized for ITEP, with the deadline later extended to 31.05.2024. The petitioner College applied for the fourth phase of ITEP on 18.05.2024 for the academic year 2025-26. Following inspection, the NCTE issued a Letter of Intent on 03.04.2025, requiring submission of specific documents within 60 days to obtain formal recognition under Clause 7(16) of the NCTE Regulations 2014. Although the College submitted all required documents in time, the final Recognition Order was issued only on 01.05.2025, approving courses for the academic year 2026-27.

The petitioner College filed the writ petition seeking a direction to recognize it for the academic year 2025-26 and to include it in the list of eligible institutions for admissions. The Court observed that while the College had submitted its application in time on 18.05.2024, the NCTE issued a show cause notice only on 16.10.2024, well beyond the 45-day limit stipulated by the Supreme Court in Maa Vaishno Devi Mahila Mahavidyalaya v. State of U.P. [2013(2) SCC 617]. The Court noted that the delay was entirely attributable to NCTE and not the petitioner. Despite the Letter of Intent being issued for the 2025-26 academic year, the final approval wrongfully reflected the 2026-27 academic year. The Court, in its interim order dated 02.06.2025, directed the NCTE’s Member Secretary to file a personal affidavit explaining the delay and stated that the approval year in the letter dated 01.05.2025 shall be deemed to refer to 2025-26 for admission purposes.

ISSUES:

The central issue in this case was whether the National Council for Teacher Education (NCTE) acted arbitrarily and in violation of the timeline prescribed by the Supreme Court in Maa Vaishnoo Devi Mahila Mahavidyalaya v. State of U.P. [2013(2) SCC 617] by issuing a delayed show cause notice and subsequently granting recognition for the Academic Year 2026-27 instead of 2025-26, despite the petitioner College applying well within the stipulated deadline. The petitioner sought rectification of the academic year in the Recognition Order and inclusion in the list of eligible institutions for student allotment for the 2025-26 session.

JUDGEMENT WITH REASONING:

The Court allowed the writ petition, holding that the delay in processing the petitioner’s application was solely attributable to the NCTE and not the petitioner. It directed that the impugned Recognition Order dated 01.05.2025 be treated as valid for the Academic Year 2025-26 and ordered the inclusion of the petitioner College in the list of eligible institutions for student allotment under ITEP for that academic year. All interim applications were disposed of, and no order as to costs was made.

The Court found that the National Council for Teacher Education (NCTE) had failed to comply with the timeline explicitly mandated by the Supreme Court in Maa Vaishnoo Devi Mahila Mahavidyalaya v. State of U.P. [2013(2) SCC 617], which requires the communication of deficiencies within 45 days of application submission. In this case, the NCTE issued the deficiency notice after a delay of more than three and a half months, despite the petitioner College having filed its application in a timely and proper manner. The Court observed that the petitioner promptly rectified all defects within the stipulated period once notified, demonstrating compliance and diligence. The failure to follow procedural timelines was entirely attributable to NCTE’s internal inefficiencies and not the petitioner’s fault. Moreover, the Court pointed out the irrationality in issuing a letter of intent for the Academic Year 2025-26 but later granting formal recognition for 2026-27, which lacked any reasonable justification or legal basis.

The Court emphasized that statutory bodies like NCTE are expected to function with accountability, competence, and adherence to legal norms. Any systemic inefficiency or administrative lapses on their part should not cause undue harm to educational institutions that act in good faith and fulfil all required formalities. In the present case, the NCTE had neither provided a convincing explanation for its delay nor demonstrated that the petitioner had contributed in any way to the procedural lapse. Given that the petitioner College had already established the necessary infrastructure and met all eligibility criteria for offering the Integrated Teacher Education Programme (ITEP), the denial of recognition for the intended academic year would result in unjust prejudice. Accordingly, the Court held that the recognition must be deemed valid for the Academic Year 2025-26, and directed that the College be included in the official list of eligible institutions for student allotment for the said year.

ANALYSIS:

This case highlights the procedural lapses and administrative inefficiency of the National Council for Teacher Education (NCTE) in the recognition process under the ITEP framework. The petitioner, a well-established minority institution with credible academic credentials, submitted its application well within the extended deadline and complied with all requirements, including timely rectification of deficiencies. However, NCTE failed to adhere to the timeline laid down by the Supreme Court in Maa Vaishnoo Devi Mahila Mahavidyalaya v. State of U.P., which mandates that deficiencies be communicated within 45 days. The delay of over three and a half months in issuing the show cause notice and the subsequent mislabelling of the recognition for the wrong academic year were seen as arbitrary actions. The inconsistency between the Letter of Intent and the final Recognition Order further revealed the lack of due diligence and coordination within the NCTE, causing avoidable hardship to the petitioner institution.

The judgment serves as a stern reminder to statutory bodies that adherence to legal timelines and standards is not optional but mandatory. The Court made it clear that institutions that act in good faith and fulfill all procedural formalities should not be penalized for the inefficiency or inaction of regulatory authorities. The ruling underscores the principle that bureaucratic delays, especially when they affect the functioning of educational institutions and the future of students, must be held accountable. By deeming the recognition valid for the intended academic year 2025-26 and ensuring the College's inclusion in the eligible institutions list for student allotment, the Court prioritized fairness and upheld the rule of law. The judgment also sends a message that regulatory bodies must act with transparency, efficiency, and responsibility in implementing national educational reforms like ITEP.