In a significant judgment, the Allahabad High Court ruled that students with intermediate qualifications (Class 12) are eligible for admission into the Diploma in Elementary Education (D.El.Ed.) course. The Court quashed a controversial government order that mandated graduation as the minimum eligibility for the course in government institutions, terming the condition arbitrary and discriminatory. The verdict was delivered in the case Writ-C No. 24528 of 2024, filed by Yashank Khandelwal and nine others, challenging the new admission criteria introduced by the Uttar Pradesh Government.
Background of the Case:
The case arose after the State Government issued a Government Order (GO) on 09.09.2024, which raised the minimum educational qualification for D.El.Ed. admissions in government-run institutions like the District Institute of Education and Training (DIET) from intermediate (Class 12) to graduation. This order was seen as discriminatory, especially when the qualification for admission into similar D.El.Ed. programs in private institutions remained intermediate. The petitioners, all intermediate graduates, argued that this condition would delay their eligibility for teaching positions, forcing them to complete both the D.El.Ed. course and a graduation degree before being considered for jobs.
Legal Issues Involved:
The petitioners’ main contention was that the Government Order violated Article 14 of the Indian Constitution, which guarantees equality before the law. They argued that while the government-run institutions required graduation for admission into the D.El.Ed. course, the private institutions and special education programs under the same banner continued to admit intermediate-passed students. This, they claimed, created an unjust “class within a class,” discriminating against students who were not graduates.
The petitioners also pointed out that students in private institutions, who were allowed to pursue graduation and the D.El.Ed. course simultaneously, would be eligible for teaching positions within three years, while those admitted to DIET institutions would have to wait five years to be eligible due to the new qualification requirement.
Court’s Observations and Ruling:
Justice Manish Kumar, who presided over the case, emphasized that the Court could interfere in policy decisions only when they were unconstitutional or in violation of statutory provisions. The Court, quoting several precedents, including Delhi Development Authority vs. Joint Action Committee and State of West Bengal vs. Anwar Ali Sarkar, held that any classification must have a rational basis and a clear nexus with the objective it seeks to achieve. In this case, the differentiation between intermediate and graduate students for the same course did not meet these criteria.
Justice Kumar stated:
“The State has created a class within a class, which is not permissible and violative of Article 14 of the Constitution. There is no rational nexus between the requirement of a graduation degree for admission to the D.El.Ed. course and the purpose sought to be achieved by the Government.”
The Court observed that while the State was empowered to prescribe higher qualifications, this particular condition had no reasonable justification, especially since the requirement for graduation is relevant for appointment as a teacher, not for admission to a training program. The Court also noted that the petitioners, by being forced to meet a higher qualification standard, would face undue delays in their career progression compared to their counterparts in private institutions.
Decision of the Court:
The Allahabad High Court quashed the impugned clause in the Government Order, allowing intermediate-passed students to be admitted into the D.El.Ed. course in government-run DIET institutions. The Court, however, allowed the admission process, which was already underway, to continue and directed that the petitioners be allowed to participate.
Justice Kumar ruled that:
“The impugned clause 4 in the Government Order dated 09.09.2024 to the extent for imposing the condition of graduation in the D.El.Ed. 2024 course is hereby quashed with prospective effect, as the selection process has already started.”
Case Title: Yashank Khandelwal and 9 Others vs. State of Uttar Pradesh and 3 Others
Case No.: Writ-C No. 24528 of 2024
