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Tripura HC Mandates TET Certificate Issuance for Candidates Pursuing Training During Exam

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The Tripura High Court has fortified the rights of teacher candidates, ruling that a student pursuing a teacher-training course at the time of the Teachers Eligibility Test cannot be denied a certificate upon subsequent qualification. The Court held that withholding certificates from candidates who eventually clear their professional degrees violates the mandate of equality and fairness.

Justice Biswajit Palit presided over the matter, evaluating the Petitioner's grievance against the Teachers Recruitment Board, Tripura (TRBT). The Petitioner, who appeared for the T-TET 2024 as an 'appearing candidate' while pursuing a D.El.Ed course, was denied a certificate despite securing the requisite qualifying marks. The Tripura High Court scrutinized whether the TRBT could cancel candidatures based on the timing of producing final mark sheets, especially when the candidates fulfilled academic requirements during the process.

Key Takeaways

Retroactive Eligibility Validation

Candidature cannot be dismissed solely because professional results were pending at the time of the TET exam if the candidate subsequently acquires the degree.

NCTE Guideline Supremacy

State recruitment agencies must strictly adhere to the Right Of Children To Free And Compulsory Education Act (RTE), 2009 and its corresponding guidelines, which permit 'pursuing' students to appear for eligibility tests.

Equal Treatment Doctrine

Authorities are bound by the principle that similarly situated persons must be granted identical relief to avoid constitutional discrimination.

Court's Rationale on Article 14 Violation

The Court observed that the Petitioner had successfully secured 88 marks in the T-TET but was excluded from the final list of qualified candidates. The Bench highlighted that the Respondent Authority failed to prove that a candidate pursuing a teacher-training course provisionally was ineligible to be issued a T-TET certificate upon acquiring the requisite qualification. The Court, in its reasoning, observed: "this Court finds that the Respondent Authority has acted in violation of Article 14 of the Constitution of India by refusing to issue the T-TET Certificate in favour of the Petitioner, who is otherwise entitled to the same."

The Court has following directions:

"Consequently, the Respondent-TRBT Authority is directed to issue the T-TET Certificate in favour of the Petitioner within a period of three (3) months from the date of passing of this judgment, after affording the Petitioner an opportunity to produce the final mark sheet of the D.El.Ed. Course, provided that the Petitioner fulfills all the prescribed criterias."

Ratio

A candidate who is 'pursuing' a recognized teacher education course at the time of the Teachers Eligibility Test (TET) is eligible to appear for the exam. Upon the successful completion of the said professional course and securing the qualifying marks in the TET, the state authorities cannot withhold the eligibility certificate. Any clause in a prospectus that mandatorily requires the production of a final pass certificate at the time of scrutiny for 'appearing' candidates, without allowing for subsequent acquisition, is secondary to the Right Of Children To Free And Compulsory Education Act (RTE), 2009 and the Constitution of India.

Background

The Petitioner enrolled in a D.El.Ed. program for the 2023-2025 session and applied for the T-TET 2024 under a prospectus that provisionally allowed appearing candidates. While he qualified with 88 marks, the TRBT excluded him from the final qualified list on 13.12.2025, citing a clause that required final pass mark-sheets during scrutiny. The Petitioner argued that this was contrary to State of Uttar Pradesh & Ors. v. Arbind Kumar Srivastava & Ors. ( "(2015) 1 SCC 347": 2014 CaseBase(SC) 808), where the Apex Court held that similarly situated persons must be treated alike. The State-respondents relied on an earlier Division Bench ruling in a separate Writ Appeal, arguing the prospectus was mere publicity material and the petition was speculative. However, the Tripura High Court distinguished the facts, noting the Petitioner had now completed his course and that the Right Of Children To Free And Compulsory Education Act (RTE), 2009 guidelines dated 11.02.2011 explicitly allowed persons pursuing TTC courses to appear for TET. Consequently, the Court allowed the writ petition.

Case Details:
Case No.: WP(C) No. 28 of 2026
Neutral Citation: 2026:THC:1232
Case Title: Sri Priyatosh Das v. The State of Tripura & Ors.
Appearances:
For the Petitioner(s): Mr. Arijit Bhaumik, Advocate; Ms. Ishpa Chakma, Advocate; Ms. Priyanka Chakraborty, Advocate.
For the Respondent(s): Mr. Karnajit De, Addl. GA.

Source: 2026 CaseBase(TRI) 512