Dismissed¶20

Mrs. Saroj v. Union of India, through Secretary, Ministry of Tribal Affairs & Anr.

Delhi HC8 Apr 2026W.P.(C)/4604/2026

Case brief

AI extract

What is this about?

B.Ed. (Special Education) vs B.Ed. equivalence; RCI recognition; ESSE-2023 TGT (Social Science) final result dated 05.05.2025; exclusion of candidature; NCTE Regulations 2001 superseded by NCTE Regulations 2014; NCTE clarifications/circulars; GNCTD & Ors. v. Uma Rani & Ors (W.P.(C) 700/2023, Div. Bench); W.P.(C) 33/2026 order dated 23.03.2026; petition dismissed as withdrawn with liberty to challenge regulatory framework; merits not examined; rights and contentions left open; Delhi High Court; Justice Sanjeev Narula; 08.04.2026.

What did the court decide?

Dismissal as withdrawn with leave and liberty to avail appropriate remedies in accordance with law, including laying a challenge to the relevant regulatory framework; all rights and contentions left open. ¶20

Mrs. Saroj Vs Union of India, through Secretary, Ministry of Tribal Affairs & Anr. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

¶20

Issue for consideration

Whether the qualification of B.Ed. (Special Education), recognised by the Rehabilitation Council of India (RCI), is equivalent to the B.Ed. degree prescribed under the recruitment notification issued by Respondent No. 2. +2 more

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Ratio / Principle

Leave and liberty, as prayed for, are granted to withdraw the present petition with liberty to avail appropriate remedies in accordance with law, including laying a challenge to the relevant regulatory framework.

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Key takeaways

The petition is dismissed as withdrawn, along with pending application(s), if any.ratio¶20
The Court clarified that it has not examined the merits of the case; all rights and contentions of the parties are left open, and observations made shall not be construed as an expression of opinion on the merits.obiter¶21

Detailed headnote1 paragraphs

W.P.(C) 4604/2026, High Court of Delhi at New Delhi (Sanjeev Narula, J.), order dated 08.04.2026 — Petitioner (Mrs. Saroj), excluded from the final result dated 05.05.2025 for TGT (Social Science) under the EMRS Staff Selection Examination (ESSE-2023), contested the non-equivalence of her B.Ed. (Special Education) recognised by the Rehabilitation Council of India with the prescribed B.Ed., relying on GNCTD & Ors. v. Uma Rani & Ors (Div. Bench, W.P.(C) 700/2023, decided 05.12.2025). Respondents countered that Uma Rani rested on the NCTE Regulations, 2001, now superseded by the NCTE Regulations, 2014, supported by NCTE clarifications and an order dated 23.03.2026 in W.P.(C) 33/2026. Petitioner sought withdrawal with liberty to challenge the regulatory framework; leave and liberty granted, petition dismissed as withdrawn. The Court expressly did not examine the merits and left all rights and contentions open.

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$~89

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 4604/2026

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MRS. SAROJ .....Petitioner

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Through: Mr. Abhay, Advocate.

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versus

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UNION OF INDIA, THROUGH SECRETARY, MINISTRY OF TRIBAL AFFAIRS & ANR. .....Respondents Through: Mr. Ishkaran Singh Bhandari, CGSC with Mr. Piyush Yadav, Advocates for R-1 & 2. Mr. Somesh Chandra Jha, Advocate for R-2.

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CORAM:

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HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R % 08.04.2026

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This petition impugns the final result dated 05^th May, 2025, whereby the Petitioner’s candidature for the post of TGT (Social Science) under the EMRS Staff Selection Examination (ESSE-2023) has been excluded.

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The principal issue that arises for consideration pertains to the equivalence of the qualification of B.Ed. (Special Education), recognised by the Rehabilitation Council of India (“RCI”), with a B.Ed. degree as prescribed under the recruitment notification issued by Respondent No. 2. 3. Counsel for the Petitioner places reliance upon the judgment of the Division Bench of this Court in GNCTD & Ors. v. Uma Rani & Ors . ,¹ to

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1 In W.P.(C) 700/2023 , decided o 05th December, 2025.

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/04/2026 at 12:26:18

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contend that in the absence of any express exclusion in the advertisement, candidates possessing B.Ed. (Special Education) cannot be denied consideration.

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Per contra , counsel for the Respondents submits that the judgment in Uma Rani , proceeded on the basis of the NCTE Regulations, 2001, which now stand superseded by the NCTE Regulations, 2014 governing the field. He further relies on subsequent clarifications/circulars issued by NCTE, indicating that B.Ed. (Special Education) is not to be treated as equivalent to B.Ed. (General) for appointment in regular schools. Reliance is also placed on the order of this Court dated 23^rd March, 2026 in W.P.(C) 33/2026 , where the aforesaid position has been noted in the context of a similar controversy.

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In view of the above, counsel for the Petitioner submits that he seeks to adopt a similar course as was taken in W.P.(C) 33/2026 , and accordingly prays for leave to withdraw the present petition with liberty to avail appropriate remedies in accordance with law, including laying a challenge to the relevant regulatory framework.

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Leave and liberty, as prayed for, are granted.

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The petition is accordingly dismissed as withdrawn, along with pending application(s), if any.

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It is clarified that this Court has not examined the merits of the case. All rights and contentions of the parties are left open. Any observations made herein shall not be construed as an expression of opinion on the merits of the case.

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SANJEEV NARULA, J

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APRIL 8, 2026/ab

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/04/2026 at 12:26:18

Mrs. Saroj v. Union of India, through Secretary, Ministry of Tribal Affairs & Anr.

Case brief

What is this about?

What did the court decide?

Mrs. Saroj v. Union of India, through Secretary, Ministry of Tribal Affairs & Anr.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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