1. The Rajasthan Panchayati Raj Rules prescribe a minimum qualification of B.A./B.Sc. plus B.Ed. for Level-I teachers. A temporary relaxation was notified to allow B.Ed. holders to be appointed only until 1.1.2012, subject to completing a special program subsequently.
2. The Supreme Court has held that B.Ed. qualification is not a higher qualification than TTC because the training for teaching small children at the primary level differs from the specialized training for higher classes. Mere past deviations or availability of B.Ed. candidates do not justify ignoring statutory rules or recruiting ineligible persons.
3. Under Section 23(2) of the Right of Children to Free and Compulsory Education Act, 2009, the Central Government can grant relaxation in qualifications for a maximum of five years only if a State lacks sufficient institutions or qualified candidates. In this case, neither circumstance existed in Rajasthan to warrant such relaxation.
4. Mere appearance or qualification in the Teacher Eligibility Test (TET) does not confer eligibility for appointment if the applicant lacks the qualifying degree prescribed by statute. The judicial power to relax services rules is limited; it cannot be exercised to modify statutory provisions without a challenge to their validity.
5. The cut-off date of 1.1.2012 for the change in qualification requirements was not challenged by the petitioners. Consequently, no judicial direction can be issued to treat B.Ed. holders as eligible for appointment after this date. The writ petitions challenging the refusal to relax these criteria were dismissed.