Delhi HC upholds CAT orders allowing B.Ed. (Special Education) candidates for TGT/PGT posts

New Delhi [India], December 15 : The Delhi High Court has declined to interfere with a series of Central Administrative Tribunal (CAT) orders that recognised candidates holding B.Ed. (Special Education) as eligible for appointment to Trained Graduate Teacher (TGT) and Post Graduate Teacher (PGT) posts, noting that the recruitment advertisements never excluded them from consideration.
A Division Bench comprising Justices Navin Chawla and Saurabh Banerjee dismissed multiple petitions filed by the Government of NCT of Delhi and the Delhi Subordinate Services Selection Board, which had challenged CAT decisions favouring such candidates across several selection processes.
The Court emphasised that the advertisements in question merely required a "degree/diploma in teaching" and did not restrict eligibility to holders of B.Ed. (General). In the absence of any express exclusion, the Bench held that authorities could not subsequently deny eligibility to candidates with B.Ed. (Special Education).
Addressing the government's argument that B.Ed. (General) and B.Ed. (Special Education) because the qualifications are distinct and non-equivalent, regulated by different statutory bodies, the Court observed that the debate on equivalence was misplaced. It clarified that once the recruitment notice itself did not limit eligibility, the issue of comparing or equating the two degrees became irrelevant.
The Bench also relied on the Rehabilitation Council of India's (RCI) position, which held that candidates trained in special education are competent to teach both general students and children with disabilities. Such candidates, the RCI said, are in fact additionally trained and should not be excluded from mainstream teaching roles.
The Court rejected the reliance placed by the petitioners on Supreme Court rulings dealing with qualification equivalence, distinguishing those cases on the ground that they involved advertisements with specific and restrictive eligibility conditions. In contrast, the present cases arose from broadly worded advertisements for general teaching posts.
Reiterating its earlier observations in Social Jurist v. Government of NCT of Delhi, the High Court noted that B.Ed. (Special Education) Qualifications have previously been recognised alongside general education degrees, particularly in the context of inclusive education.
Finding no legal infirmity in the CAT's reasoning, the High Court dismissed all the petitions and upheld the eligibility of B.Ed. (Special Education) candidates for the advertised TGT and PGT posts, without imposing any costs.