Delhi High Court Upholds Eligibility of B.Ed (Special Education) Holders for TGT/PGT Posts
The Delhi High Court on Thursday dismissed a batch of writ petitions filed by
the Government of NCT of Delhi and the Delhi Subordinate Services Selection
Board (DSSSB), holding that candidates possessing a Bachelor of Education
(B.Ed.) degree in Special Education are eligible to apply for Trained
Graduate Teacher (TGT) and Post Graduate Teacher (PGT) posts where the
recruitment advertisement prescribes a “degree/diploma in teaching” without
expressly excluding such qualification.
A
Division Bench comprising Justice Navin Chawla and Justice Saurabh Banerjee
upheld the orders of the Central Administrative Tribunal (CAT), Principal
Bench, which had allowed the applications filed by several candidates,
including Ms. Uma Rani. The Court affirmed that the Tribunal had correctly
interpreted the recruitment advertisements issued by the authorities.
The
Court noted that the relevant advertisements did not mandate that only
candidates holding B.Ed. (General) degrees would be eligible, nor did they
exclude candidates with B.Ed. (Special Education). In such a situation, the
Bench observed, the issue of equivalence between the two qualifications becomes
irrelevant, as the only requirement mentioned was a “degree/diploma in teaching.”
The
Bench rejected the reliance placed by the petitioners on certain Supreme Court
judgments and clarifications issued by the National Council for Teacher
Education (NCTE). Instead, the Court relied upon the affidavit of the
Rehabilitation Council of India (RCI), the statutory regulator for special
education, which stated that holders of B.Ed. (Special Education) are
professionally trained to teach both general students as well as children with
disabilities, and therefore should not be denied appointment to general
teaching posts.
Distinguishing
earlier Supreme Court decisions cited by the government, the High Court held
that those cases involved advertisements with specific and restrictive
qualification requirements, unlike the present case where no such exclusion was
prescribed in the recruitment notification.
The
Court accordingly dismissed all the writ petitions and pending applications,
with no order as to costs. The case of Ms. Uma Rani before the Delhi High Court
was argued on her behalf by Mr. Anuj Aggarwal, Advocate, along with his team.
The judgment is expected to have a significant impact on future teacher
recruitment processes in Delhi, particularly for candidates trained in special
education seeking appointment to general teaching posts.
Govt.
of NCT of Delhi & Ors. Vs. Ms. Uma Rani & Anr. [WPC No. 700/2023, Delhi
High Court (Division Bench), decided on – 05 December 2025]
https://advocateanujaggarwal.com/home.php
Anuj
Aggarwal
Advocate
K-17,
2nd Floor, Jangpura Extension,
New
Delhi - 110014
483,
Block-2, Lawyers Chambers,
Delhi
High Court, New Delhi-110003
Mobile
– 9891403206
Landline
– 011 - 35554905
Email
– anujaggarwal1984@gmail.com




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