Chhattisgarh High Court rejects B.Ed. relaxation for Agriculture Teacher recruitment, citing mandatory eligibility rules and NCTE regulations.

News Citation : 2026 LN (HC) 428

August 20, 2026 : The Chhattisgarh High Court has refused to grant one-time relaxation from the mandatory B.Ed. qualification to candidates seeking appointment as Teacher (Agriculture). Justice Bibhu Datta Guru, hearing WPS No. 6260 of 2026, held that courts cannot waive mandatory eligibility conditions prescribed by the competent rule-making authority merely to accommodate individual candidates.

The petition was filed by 65 candidates who sought permission to participate in the ongoing recruitment process despite not possessing the prescribed B.Ed. qualification. They argued that under the eligibility framework prevailing since 2019, B.Ed. was not mandatory for the post of Teacher (Agriculture). According to the petitioners, the requirement was subsequently introduced following the Division Bench judgment in Ashokanand Patel & Others v. State of Chhattisgarh & Others, decided on February 5, 2025. The State Government thereafter issued a Gazette Notification dated February 13, 2026, making B.Ed. qualification mandatory for the post.

The petitioners did not challenge the State Government’s authority to prescribe B.Ed. as a qualification. Their grievance was that the new requirement had been applied to the present recruitment without providing candidates with a reasonable transitional period. They pointed out that the recruitment advertisement was issued on July 28, 2026, with September 2, 2026 as the last date for applications, whereas completion of the B.Ed. course requires two academic years. They therefore sought permission to participate in the recruitment subject to acquiring the B.Ed. qualification within a period prescribed by the Court or the authorities.

The State Government and the Chhattisgarh Staff Selection Board opposed the plea. They argued that candidates could not claim relaxation from qualifications prescribed under the applicable Rules and NCTE Regulations. The State also relied on the earlier Division Bench judgment in Ashokanand Patel, under which the exemption from the prescribed qualification for Agriculture Teachers had been declared unconstitutional and ultra vires. The State Government had been directed to include the B.Ed. qualification in accordance with the NCTE Regulations, 2014.

The High Court accepted the respondents’ position. It observed that once the earlier exemption had been declared unconstitutional and the State had been directed to prescribe B.Ed. qualification in accordance with the NCTE Regulations, candidates could not claim a right to participate in the recruitment without possessing the qualification required under the prevailing Rules.

The Court further held that granting the requested relaxation through a judicial order would effectively create an exception to a mandatory qualification that had been prescribed pursuant to the binding decision of the Division Bench. The Court emphasised that “fixing eligibility criteria, minimum qualifications, and service rules belongs strictly to the rule-making authority” and that courts cannot substitute their own views for those of the competent authority.

The judgment also reiterated the limited scope of judicial review under Article 226 of the Constitution. The High Court noted that its writ jurisdiction is primarily concerned with examining whether governmental action is arbitrary, mala fide or unconstitutional. It cannot ordinarily be used to waive mandatory recruitment qualifications or create special eligibility conditions for individual candidates.

The Court therefore found no ground to grant the one-time transitional relaxation sought by the petitioners. Relying on the binding nature of the earlier Ashokanand Patel judgment, Justice Bibhu Datta Guru dismissed WPS No. 6260 of 2026 at the motion stage on August 20, 2026.

The ruling is significant for the ongoing Teacher (Agriculture) recruitment in Chhattisgarh. It makes clear that candidates must satisfy the eligibility requirements prescribed under the prevailing recruitment rules and that courts will not ordinarily dilute mandatory educational qualifications on grounds of individual hardship or the absence of a transitional period.