(Prayer: Writ Petition filed under Article 226 of the Constitution of India for the issuance of Writ of Mandamus, directing the respondents to permit the petitioner to continue the M.Ed. Program for the academic year 2025-2027 in the third respondent College, for which she was already admitted after verification of certificates and payment of fees, without insisting upon any additional or illegal eligibility condition.)

1. This writ petition is filed for a mandamus directing the respondents to permit the petitioner to continue the M.Ed. programme for the academic period 2025–2027 in the third respondent college, for which she was already admitted and her certificates were also verified and payment of fees was made.

2. Upon hearing the learned Counsel for the petitioner and perusing the affidavit filed in support of the writ petition and the other material records of the case, it can be seen that she possesses an undergraduate degree of B.A. in Economics, which she completed from Annamalai University with 57% marks, and thereafter she did her B.Ed. from Senthil College of Education, Pondicherry, which is affiliated to Pondicherry University and she passed with 76% marks. While so, when she applied to the third respondent college, namely Our Lady College of Education, Maduravoyal, Chennai, to undergo the M.Ed. programme in the subject of Economics for the academic period 2025–2027, she was called for the selection process and her certificates were verified and a fee of Rs.20,000/- was also collected from her on 04.06.2025. Thus, her admission was confirmed and she was also inducted into the WhatsApp group of the college for participating in the academic activities, including attending workshops before the commencement of classes. When this was so, suddenly she was removed from the WhatsApp group and was also informed that her admission could not be continued since she did not possess the educational qualification of M.A. in Economics and no written order was passed. Under these circumstances, the petitioner is before this Court.

3. The learned counsel for the petitioner would submit that when her admission was duly completed and when her B.Ed degree was awarded by Pondicherry University in accordance with law, there was no occasion for the respondents to insist upon the qualification of M.A. in Economics for the purpose of admission into the M.Ed. course.

4. The learned Counsel appearing on behalf of the first respondent University would rely upon G.O.(D).No.112 dated 20.05.2025 of the Higher Education (G1) Department and submit that the guidelines for admission to B.Ed. and M.Ed. degree programmes are contained therein. A perusal of the same, particularly paragraph No.1, would show that the B.Ed. programme is being offered in the State of Tamil Nadu with reference to 19 major subjects. The subject of Economics falls under Serial No.12. Under the same guidelines, it can be seen that with reference to subject codes in Serial Nos.1 to 10, it is sufficient if the candidates have an Undergraduate degree with not less than 50% marks so as to get admitted into the B.Ed. course. As far as subject codes in Serial Nos.11 to 19 are concerned, the essential qualification is that the candidates should have a postgraduate degree with 50% marks so as to get admission in the B.Ed. degree. Though the criteria for admission into M.Ed. generally requires a B.Ed. degree, the learned Counsel would submit that the name B.Ed. itself would not suffice, but it should be equivalent and the University is entitled to consider the same.

5. The learned counsel would submit that as per the regulations of the Government of Tamil Nadu adopted in the admission process within the State of Tamil Nadu, a candidate undergoing the B.Ed. degree should have a Postgraduate degree in Economics as a mandatory eligibility criterion and since the petitioner does not possess the said qualification, granting admission to the M.Ed. course does not arise. The learned Counsel for the first respondent would further rely upon the notification dated 28.11.2014 issued by the National Council for Teacher Education, the second respondent herein, more specifically Regulation 3.3, which categorically states that admission shall be as per the policy of the State Government or the Union Territory administration. Even on a cumulative reading of the guidelines and the notification, it can be seen that the University has to ensure that the B.Ed. degree is also a valid B.Ed. degree so as to grant admission and since the petitioner did not possess the same, her admission was not approved and therefore the college relieved her even before the Course started.

6. The learned Counsel appearing on behalf of the second respondent would submit that the second respondent has laid down the national standards and that as per the same, for enrolment in any speciality or subject of B.Ed., the essential qualification is only an undergraduate degree. The States or Union Territories in some subjects prescribe higher qualifications depending on their decision.

7. The learned counsel appearing for the third respondent College would submit that since the admission of the candidate was objected to by the first respondent University, she was relieved from the course and that even now the college has one vacancy and will abide by any further directions issued in this case.

8. The learned counsel appearing on behalf of the fourth respondent Pondicherry university would place reliance on the regulations and syllabus for the two years B.Ed. degree program that is framed by the Pondicherry university and Paragraph No.1 of the said regulations prescribes only the undergraduate degree for B.Ed in the subject of economics. As far as Pondicherry University is concerned, only for the subjects of Psychology, Sociology and Philosophy, Commerce, Computer Science and Home Science are the candidates required to possess both Bachelor’s and Master’s degrees in the same subject. For the other courses, only a Bachelor’s degree is the essential qualification and as far as Economics is concerned, it is sufficient if the candidate possesses an undergraduate degree with 50% marks. The present candidate satisfied the criteria and therefore she was duly admitted into the B.Ed. programme and the degree has been awarded and there is no error whatsoever in the B.Ed. degree.

9. I have considered the rival submissions made on either side and perused the material records of the case.

10. In this case, we are concerned with admission to the M.Ed. programme. It is essential to advert to the regulations framed by the second respondent vide Notification dated 28.11.2014, called the National Council for Teacher Education (Recognition Norms and Procedure) Regulations, 2014. It is necessary to extract Regulation 3.3 for ready reference:-

                     “3.3 Admission Procedure

                     Admission shall be made on merit on the basis of marks obtained in the qualifying examination and/or in the entrance examination or any other selection process as per the policy of the State Government/U.T. Administration and the University.”

11. As far as the selection process is concerned, whether by entrance examination or qualifying examination or any other process, the policy of the concerned State Government has to be followed. As far as the policy of the State Government with reference to admission to the M.Ed. programme is concerned, the same is contained in the guidelines issued vide G.O.Ms.No.112 referred to above.

12. The eligibility for admission is prescribed in Regulation 4.2 of the Regulations and the same is extracted for ready reference:

                     4.2 Eligibility

                     (a) Candidates seeking admission to the M.Ed. Programme should have obtained at least 50% marks or an equivalent grade in the following programmes:

                     (i) B.Ed.

                     (ii) B.A.B.Ed., B.Sc.B.Ed.

                     (iii) B.El.Ed.

                     (iv) D.El.Ed. with an undergraduate degree (with 50 % marks in each)

                     (b) Reservation and relaxation for SC/ST/OBC/PWD and other applicable categories shall be as per the rules of the Central Government/State Government whichever is applicable.

13. Thus, it can be seen that any candidate possessing a B.Ed. degree can be admitted into the M.Ed. programme. As far as the Government guidelines are concerned, the same are extracted hereunder for ready reference.

                     “IX. Procedure for admission to M.Ed. Programme

                     Application fee for M.Ed. Programme fixed as Rs.58/- (Rupees Fifty Eight only) + Rs.2/- (Rupees Two Only) as registration fee for each college applied. For SC/SCA/ST candidates, there is no application fee but registration fee of Rs.2/- is to be paid.

                     For admission to M.Ed. Programme (PG) a candidate must have passed B.Ed. Programme recognised by the University.

                     In case of admission to M.Ed. Programme in all colleges including Government/Government Aided and Self-Financing Colleges the date of registration for admission and last date of registration of online application will be notified separately.

                     Reservation of seats for candidates will be followed as per B.Ed. Programme guidelines.

                     The basis of selection shall be in accordance with the Regulations of the University/Government of Tamil Nadu Guidelines for admission to M.Ed., degree programme in force from time to time.”

14. Thus, it can be seen that for admission to the M.Ed. programme, the candidate should have passed a B.Ed. programme recognised by the University. As far as the present candidate is concerned, she possesses a B.Ed. degree. It is not the case that the B.Ed. degree awarded by Pondicherry University, which is a University created and established under an Act of Parliament and regulated by the Central Government, is not a recognised degree. It is only the contention of the first respondent University that since, at the time of admission into the B.Ed. course, the essential criteria were different from those in the State of Tamil Nadu, namely non-possession of a postgraduate degree, they will not admit the petitioner. Therefore, this does not amount to non-recognition of the B.Ed. degree itself, but relates only to the petitioner.

15. It is true that the State of Tamil Nadu can prescribe its own guidelines; however, such guidelines cannot operate extra-territorially. When it comes to its own employment, it can verify whether the prescribed criteria are complied with or not. However, when another University, which is a duly recognised institution functioning in accordance with law, has different regulations prescribing an undergraduate degree for the subject of Economics, admission cannot be denied to the petitioner when she possesses a B.Ed. degree with 50% or more marks, which alone is the essential criterion for admission. Once there is a valid B.Ed. degree with the requisite percentage, the first respondent University cannot further enquire into whether the petitioner’s admission into the B.Ed. degree was in accordance with the procedure laid down by the Government of Tamil Nadu. Obviously, Pondicherry University is a Central University and is bound by the norms prescribed by the Central Government or the Union Territory Administration and by it’s own statutues.

16. In view of the peculiar facts and circumstances of the case, I am of the view that the course adopted by the first respondent University is unsustainable. It is brought to the notice of the Court that there is one more vacancy in the third respondent College and therefore, if further directions are issued, the student can continue her education.

17. In view thereof, this writ petition is allowed on the following terms:

(i) The action of the respondents in relieving the petitioner from the M.Ed. course in the third respondent College is declared illegal.

(ii) The petitioner shall report to the third respondent College forthwith and the third respondent College shall permit her to continue the M.Ed. degree and it will be open to the college to send any other formal documents required to the first respondent University.

(iii) The first respondent University shall treat the admission of the petitioner as valid and shall process her further studies and academic credentials accordingly.

(iv) The authorities shall act on the web copy of the order without waiting for the certified copy of the order and the petitioner shall not be prejudiced on account of non-attendance of classes until the date of receipt of the web copy of the order.

(v) The third respondent College, in respect of the lessons already completed, can consider imposing special assignments and conducting special classes for the petitioner so that she can cope up and satisfy the attendance and credit requirements before appearing for the examination.

(vi) Consequently, connected miscellaneous petition is closed. No costs.