Dr. Radhakrishan Tt College & Anr v. National Council for Teacher Education & Anr

O R D E R %

06.07.2026

¶1The petitioners have approached this Hon'ble Court seeking the following prayers: "a. Issue a Writ of mandamus or any other suitable writ or order or direction to respondents to conduct inspection of petitioner institute and decide its application for recognition of conversion/transition of existing 4 year integrated B.A.B.Ed/B.Sc.B.Ed to ITEP course from present academic session 2026-27 expeditiously and in time bound manner: and/or b. Pass any such other orders/directions as this Hon'ble Court deems fit and proper in the facts and circumstances of the case..."

¶2The case of the petitioners is that: a. Pursuant to invitation of application by NCTE, petitioner No.2 submitted its application seeking recognition of B.A.B.Ed/B.Sc.B.Ed course. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. b. After scrutiny/evaluation of petitioners' application, inspection of petitioners institution, Western Regional Committee ("WRC") vide its order dated 27.10.2021 granted recognition to conduct B.A.B.Ed/B.Sc.B.Ed 4-year integrated course with an annual intake of 100 Seats (two basic units) from academic session 2022-23. c. As things stood, the NCTE issued guidelines dated 15.05.2025 for transforming NCTE recognized standalone teacher education institutions into Multidisciplinary Higher Education Institution and pursuantly issued public notices dated 25.08.2025 &

12.09.2025 directing existing recognized institutions which have been running 4 years integrated B.A.B.Ed/B.Sc.B.Ed course to submit fresh application for transition. d. Accordingly, pursuant to aforesaid public notices issued by NCTE, the petitioners submitted fresh online application to NCTE on 03.10.2025. e. Alongwith the application, the petitioners submitted all relevant documents pertaining to physical and academic infrastructure of the institute such as certified copy of land documents, mutation certificate of land, land use certificate, non-encumbrance certificate, approved building plan, site plan, building safety certificate, fire safety certificate etc.

¶3Mr. Kumar, learned counsel for the petitioners submits that despite the fact that the petitioners institute is an existing institute duly recognized by WRC for running 4 year integrated B.A.B.Ed/B.Sc.B.Ed course, WRC vide its order dated 18.11.2025 refused the said application dated

03.10.2025 without issuing any Show Cause Notice.

¶4That being aggrieved, the petitioners approached this Hon'ble Court by filing W.P. (C) No. 18844/2025 praying as under:- The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. a. "quash the Refusal Order dated 18.11.2025 issued by the respondent No.2 (through email dated 18.11.2025), whereby, the respondent No.2 has refused the application of the petitioner Institution submitted for transition of its B.A. B.Ed./ B.Sc. B.Ed. course to ITEP, for the academic session 2026-27; without following the mandatory procedure; and b. direct the respondent No.2 to restore, reconsider & decide the aforesaid application of petitioner Institution, submitted for transition of its B.A. B.Ed. / B.Sc. B.Ed. course to ITEP, for the session 2026-27; within a reasonable time & in accordance with the provisions made therefore."

¶5The Learned Counsel for the petitioners has shown me the order passed by this Hon'ble Court, which vide its final order dated

11.12.2025 disposed off the aforesaid writ petition by setting aside refusal order dated 18.11.2025 with direction to process petitioners' application with following observations:- "Accordingly, without going into the merits of the case, this writ petition is allowed to a limited extent of setting aside impugned order dated 18.11.2025 on the ground that it was passed without affording reasonable opportunity to the Petitioner to make a written representation. It will be open to the Respondents to issue a show cause notice to the Petitioner pointing out deficiencies/shortcomings and calling upon the Petitioner to make a written representation. On receipt of the show cause notice, Petitioner shall submit its response within two weeks from the date of receipt and thereafter, it will be open to the Respondents to pass a fresh order in accordance with law and after considering the representation. The order shall be passed within two weeks and communicated to the Petitioner. Needless The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. to state, the Petitioner will be at liberty to take recourse to legal remedies in case it is aggrieved by the order."

¶6He submits that though this Court had directed respondents to decide petitioners' application within a period of two weeks after submission of response to show cause, still, no order was passed by WRC in view of aforesaid order dated 11.12.2025.

¶7Mr. Kumar further submits that subsequent to this Court's order dated

11.12.2025, the petitioners institute submitted a representation dated

23.01.2026 along with copy of order dated 18.11.2025 to WRC requesting for compliance of the order. The petitioners further claim that despite directions of this Court, the WRC did not take timely steps to process the petitioner's application. It is only after a delay of nearly seven months that the WRC after considering the petitioner's application issued the First Show Cause Notice dated 18.06.2026. Admittedly, this show cause notice has been issued without any inspection having been carried out. The contents of the Show Cause Notice dated 18.06.2026 are copied below:

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

¶8Mr. Kumar submits that the grounds raised in the Show Cause Notice are such that same can only be ascertained only after carrying out inspection and some grounds in the Show Cause Notice can be clarified only after issuance of Letter of Intent ("LoI") under Regulation 7(13). He, thus, seeks a direction to respondents to conduct inspection of petitioner institute and to decide its application for recognition of conversion/transition of existing 4 year integrated B.A.B.Ed/B.Sc.B.Ed to ITEP course.

¶9That notice was issued in the aforesaid matter on 03.07.2026. Mr. Kapoor, learned Counsel for the respondents, vehemently opposes the present petition and on instructions, submits that the present writ petition is wholly premature and not maintainable at this stage.

¶10He contends that the petitioners have approached this Court at a stage where only a Show Cause Notice has been issued and no final decision has yet been taken on the petitioners' application.

¶11He submits that the issuance of a Show Cause Notice is merely an intermediary step in the decision-making process and does not, by itself, give rise to any enforceable cause of action warranting interference under Article 226 of the Constitution. According to him, unless the proceedings culminate in a final adverse order, no legal prejudice can be said to have been caused to the petitioners.

¶12The learned counsel further submits that the principal relief sought by the petitioners is a direction to the Respondents to conduct an inspection of the institution. Such a direction, according to him, would amount to compelling the Respondents to depart from the statutory procedure governing consideration of recognition applications. In this regard, he further submits that the inspection is neither an automatic consequence of filing an application, nor a matter of right but is undertaken only upon the competent authority being prima facie The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. satisfied that the applicant fulfils the threshold eligibility requirements prescribed under the Act, Regulations and the applicable Standard Operating Procedure ("SOP"). Placing reliance upon the Scheme of the NCTE (Recognition Norms & Procedure) Regulations, 2014 and the SOP governing the processing of transition applications, the learned counsel submits that the petitioners are in substance, seeking to rewrite the prescribed procedure by requesting that inspection be directed even before the deficiencies pointed out in the Show Cause Notice are examined and adjudicated upon. He further submits that such a course would render the preliminary scrutiny envisaged under the statutory framework otiose.

¶13Specifically, Mr. Kapoor further places reliance upon Regulation 7(7) of the NCTE (Recognition Norms & Procedure) Regulations, 2014 and submits that the Regional Committee is empowered to consider an application on its own merits. According to him, the expression "on its own merits" necessarily confers discretion upon the Respondents to independently scrutinize the application and satisfy themselves regarding compliance with the prescribed norms before directing any inspection. Consequently, no vested or indefeasible right accrues in favour of an applicant to seek inspection merely because an application has been submitted.

¶14On the grounds invoked in the Show Cause Notice, Mr. Kapoor submits that all the grounds are such that can be satisfactorily and adequately considered even on the basis of documents submitted by the applicant institute and that there is no requirement for a direction to conduct inspection.

¶15He submits that the writ petition deserves to be dismissed as premature, leaving it open to the petitioners to participate in the proceedings initiated pursuant to the Show Cause Notice. In the event The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. when an adverse final order is eventually passed, it would be open to the petitioners to avail the statutory remedy of appeal under Section 18 of the NCTE Act, 1993, as available in law.

¶16I have heard learned counsel for the parties and perused the material placed on record.

¶17The principal objection raised by the Respondents is that the present writ petition is premature since only a Show Cause Notice dated

18.06.2026 has been issued and no final decision has yet been taken on the petitioner's application.

¶18On my query, Mr. Kapoor does not dispute that the petitioner institute's application is still pending a final outcome. It is a matter of record that by the order dated 11.12.2025 passed in W.P.(C) 18844/2025, the WRC was directed to reconsider the case of the petitioner institution after giving it a reasonable opportunity to make a written representation. Even though the said order did not specify a time period within which this exercise was required to be done, I find it unreasonable on part of the WRC that after its consideration, the First Show Cause Notice was issued as late as 18.06.2026.

¶19Despite a clear direction by this Court in the said writ petition, there has been an unexplained delay in processing the petitioner's application in a timely manner.

¶20It is a matter of record that the petitioner is a running institution already having recognition for B.A. B.Ed./B.Sc. B.Ed. programmes, and is seeking transition to ITEP. It is also an admitted position that both B.A. B.Ed./B.Sc. B.Ed., on one hand, and ITEP, on the other hand, are integrated courses of teacher education.

¶21In my common order dated 29.05.2026 passed in W.P.(C) 4860/2026, titled Vision College of Teacher Training v. NCTE & Anr., I have The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. already observed that the infrastructural requirements of these two programmes are not substantially different.

¶22This Court is also mindful of the fact that recognition and transition matters under the NCTE regime are required to be processed within strict timelines. The Hon'ble Supreme Court in Maa Vaishno Devi Mahila Mahavidyalaya v. State of U.P. (2013) 2 SCC 617 has emphasized that the statutory schedule governing recognition of teacher education institutions is mandatory and must be scrupulously adhered to by all stakeholders. Delay in processing such applications has a direct bearing on admissions and the academic calendar, thereby affecting not merely the institution but also prospective students.

¶23In this light, I am of the opinion that even though no institution can claim inspection as a matter of right just because they submit an application; however, in paragraph No. 12 of the order in Vision College (supra) this Court has already observed as under: "12. Regulation No. 7(1) of the NCTE (Recognition Norms & Procedure) Regulations, 2014, reproduced above, shows that an application made by the institute can be rejected only (a) if it is not complete and/or (b) requisite documents are not attached to the application. In the present case, the same is not the situation. The Show Cause Notices show various non-compliances by the petitioner institution, which according to my mind can only be done after inspection. Before inspection and issuance of Letter of Intent ("LOI"), the respondents cannot be in a position to require the petitioner to show cause against deficiencies such as shortage of teaching staff, lack of physical infrastructure etc. While the respondents are right in contending that two show cause notices can be issued, but the show cause notices are in violation of Regulation No. 7 of the NCTE (Recognition Norms & Procedure) Regulations, 2014, as explained."

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

¶24Therefore, in the circumstances of the present case where the petitioner is running institute and is seeking transition from the earlier course to the new course wherein the infrastructural requirements are not substantially different, it deserves a timely and reasonable consideration of its application.

¶25The learned counsels for the parties have, at the Bar, unanimously accepted that the entrance exam for admission into ITEP programme was conducted by the National Testing Agency (NTA) on 17-

18.04.2026, and the results have been notified by NTA on 04.06.2026.

¶26It is also noteworthy that after the common order dated 29.05.2026, several petitions similar to W.P.(C) 4860/2026 have been filed and allowed on various dates during the summer-vacation by respective Coordinate Benches of this Court following the common order dated

29.05.2026. The last of such similar petitions was allowed by me on

03.07.2026, whereby it was directed that entire exercise including completion of inspection, issuance of any further Show Cause Notice, if required, consideration of the petitioner's response, and passing of a reasoned order, shall be completed on or before 10.08.2026.

¶27As such, without commenting on the validity or otherwise of the grounds invoked in the Show Cause Notice, I am of the opinion that the WRC is required to carry out a timely and expedited consideration of the petitioner institute's application. For such an expedited consideration, it is necessary that WRC is directed to inspect the petitioner institute and to notify deficiencies, if any found in one consolidated show cause notice.

¶28For the said reasons, the present petition is allowed. The respondents shall conduct inspection of the petitioner college within 4 weeks from today and shall thereafter take necessary steps to ensure that the guidelines of the Hon'ble Supreme Court are scrupulously complied The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. with. The entire exercise including completion of inspection, issuance of any further Show Cause Notice, if required, consideration of the petitioner's response and passing of a reasoned order shall be completed on or before 20.08.2026, keeping in view the timelines prescribed by the Hon'ble Supreme Court for the academic session 2026-2027.

¶29It is clarified that this order has been passed in the peculiar facts and circumstances of the present case and shall not be construed as expressing any opinion on the merits of the petitioner's application, which shall be considered independently by the respondents in accordance with law. It is also clarified that the direction for inspection shall not be construed so as to invalidate the grounds invoked in the Show Cause Notice dated 18.06.2026. Moreover, the respondents shall remain within their powers to seek the compliance of all the extant norms and conditions prescribed by it as per the applicable regulatory framework, including the grounds invoked in the Show Cause Notice dated 18.06.2026, if any deficiency is found to be persisting, subsequent to the inspection.

¶30A copy of the inspection report shall be furnished to the petitioner institute upon its preparation.

¶31The writ petition is disposed of in the aforesaid terms, along with all pending applications, if any.

JASMEET SINGH, J

JULY 6, 2026/Ni The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

* IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 8633/2026 DR. RADHAKRISHAN TT COLLEGE & ANR. .....Petitioners Through: Mr. Amitesh Kumar, Ms. Priti Kumari Vipasha Jain, Advs. versus NATIONAL COUNCIL FOR TEACHER EDUCATION & ANR. .....Respondents Through: Mr. Anuj Kapoor and Mr. Shivom Sethi, Advs. CORAM: HON'BLE MR. JUSTICE JASMEET SINGH