Tripura HC dismisses plea seeking recognition of degree for physical education teacher

The Tripura High Court has dismissed a writ petition filed by two candidates seeking a declaration that their Master of Physical Education (M.P.E.) degrees obtained from Manipur University are equivalent to the Master of Physical Education (M.P.Ed.) qualification prescribed for recruitment of Physical Education Teachers by the Teachers' Recruitment Board, Tripura (TRBT).

A single bench headed by Justice Biswajit Palit held that the petitioners failed to establish that their M.P.E. degrees were recognised as equivalent to the prescribed M.P.Ed. qualification under the applicable National Council for Teacher Education (NCTE) regulations. The court also held that the petition lacked merit and dismissed it.

The petitioners, Rubal Debnath and Pintu Debnath, had challenged their exclusion from the recruitment process initiated through a TRBT advertisement dated December 18, 2024, for 125 posts of Physical Education Teacher. They sought a direction to the authorities to treat their two-year M.P.E. degrees from Manipur University as equivalent to an M.P.Ed. degree and to consider them eligible for appointment.

The petitioners submitted that they had completed their B.P.Ed. degrees from Tripura University in 2014 and subsequently obtained M.P.E. degrees from Manipur University during the 2014-16 academic session. They argued that under the NCTE Regulations, 2001, the M.P.E. qualification was recognised for recruitment of Physical Education Teachers and that their degrees should therefore be treated as valid.

According to the petition, the candidates were allowed to appear in the written examination and were later called for document verification. They alleged that during verification they were orally informed that their M.P.E. degrees would not be treated as equivalent to M.P.Ed., although no written order was issued.

The State and TRBT opposed the petition, contending that subsequent NCTE regulations issued in 2007, 2009 and 2014 had replaced M.P.E. with M.P.Ed. as the prescribed qualification. They submitted that an Equivalence Committee examined the petitioners' qualifications and concluded that the M.P.E. degrees did not satisfy the minimum academic and professional standards required for an M.P.Ed. degree from an NCTE-recognised institution.

Respondent candidates also argued that the petitioners had secured lower marks in the recruitment examination than the selected candidates and would not qualify for appointment even if their claim regarding equivalence were accepted.

The court observed that the petitioners had not produced any material to establish that their M.P.E. degrees continued to be recognised under the applicable NCTE regulations. It also noted that the petitioners had not challenged the findings of the Equivalence Committee or impleaded the NCTE as a party to the proceedings.

Holding that the petitioners had failed to make out a case for relief, the court dismissed the writ petition and permitted the TRBT to proceed with filling the vacant posts in accordance with the applicable norms.