Rajasthan High Court Grants Relief to Teachers Demoted Over Disputed B.A. Additional Qualification | Says One-Year Course Meets Degree Equivalency Standards
Safiya Malik
The High Court of Rajasthan Single Bench of Justice Vinit Kumar Mathur declared that the B.A. Additional Course undertaken by the petitioners from Mewar University is valid and equivalent to the eligibility conditions stipulated under Schedule-1 of the Rajasthan Educational Subordinate Service (Amendment) Rules, 2008. Consequently, the Court quashed the order dated 14.04.2025 issued by the respondent authorities which had sought to revert the petitioners from the post of Senior Teachers to their previous positions on the basis of alleged qualification deficiencies. The Court held that the impugned decision was based on erroneous grounds and unsupported by the official record of the concerned university. It directed that the petitioners' promotions as Senior Teachers were proper and valid as per the applicable rules. The Court further noted that no evidence had been presented to discredit the recognition or validity of the B.A. Additional Course. As such, the petitioners were deemed to hold the requisite qualifications necessary for the post of Senior Teacher and were entitled to continue in service on the same.
The petitioners were appointed as Teacher Grade-III under the Department of Education, Government of Rajasthan. During the course of their service, they undertook a program identified as the B.A. in Additional Subject from Mewar University. Upon successful completion of the course, they were issued mark sheets by the University. Subsequently, their cases were considered for promotion, and they were elevated to the post of Senior Teacher.
The dispute arose when complaints were filed, leading the authorities to issue show-cause notices to the petitioners proposing their reversion to their original posts of Teacher Grade-III. The petitioners challenged the notices by filing a writ petition, where the Court directed the respondent authorities to seek clarification from the concerned University regarding the course structure and status of the B.A. Additional Course.
Following this directive, the petitioners submitted detailed representations, and the authorities undertook a reassessment. An order dated 14.04.2025 was passed, holding the petitioner’s ineligible for the post of Senior Teacher on the basis that the B.A. Additional Course was not equivalent to a regular degree. It was characterized as a certificate/vocational course with a duration of 90 days.
Challenging this conclusion, the petitioners argued that the course undertaken was a one-year program in a specific subject, containing all components taught over a three-year undergraduate curriculum. According to the petitioners, the University had condensed a full-fledged subject syllabus into a one-year duration for in-service teachers through distance learning, coupled with problem-solving sessions during vacations.
They further claimed that, at the time of their promotions, the authorities had treated the qualification as valid. Thus, they contended that the subsequent withdrawal of recognition was unjustified and based on a misinterpretation of facts.
In contrast, the respondent-State relied on a communication from Mewar University dated 20.06.2020, which described the B.A. Additional Course as a vocational program conducted during holidays, implying a 90-day span. Based on this, the State concluded that the course could not be equated with a full bachelor’s degree.
However, respondent No.5, Mewar University, filed a reply before the Court stating that the B.A. Additional Course was of one-year duration. The University clarified that it was a self-study program designed for teachers who could not attend regular classes and included all papers of a particular subject as covered in a three-year degree. The University denied having communicated to the government that the course was only 90 days in duration.
The central issue before the Court thus revolved around the equivalence of the B.A. Additional Course to a bachelor’s degree as prescribed under Column 4 of Schedule-1 of the Rules of 2008.
Justice Vinit Kumar Mathur recorded the factual matrix and framed the principal question as: "whether the degree or certificate of B.A. Additional Course undertaken by the petitioners from Mewar University can be treated to be equivalent to the qualifications mentioned in Column 4 of Schedule 1 of the Rules of 2008 or not?"
The Court noted: "The petitioners, while working as Teacher Grade-III, obtained a certificate/degree of B.A. Additional Course from Mewar University in different subjects. On the strength of those certificates/degrees obtained by them, the respondents considered their cases for promotion to the post of Senior Teacher."
The Court further stated: "While the petitioners were discharging their duties as Senior Teachers, they served with a show-cause notice for reverting them to the post of Teacher Grade-III." This move, according to the judgment, was based on an understanding that the course duration was 90 days.
Referring to the response from Mewar University, the Court stated: "The respondent No.5 in its reply has very categorically stated that the duration of B.A. Additional Course is one year and there is no need for any person to attend the classes since it is a distant education course on self-study mode having problem-solving session."
Further, the Court recorded: "As per the University in B.A. Additional Course all the papers of a particular subject is taught at the graduate level during three years, are taught in one year and a student has to pass all papers."
Addressing the mischaracterization by the respondent-State, the Court stated: "The foundation of the order dated 14.04.2025 is erroneous in light of the reply filed by the respondent No.5-Mewar University."
It observed that no material was presented by the State to demonstrate that the course was of 90 days' duration or that the university lacked recognition.
Regarding the eligibility requirement under the Rules of 2008, the Court noted: "As per the requirement mentioned in Schedule-1 of the Rules of 2008, it clearly shows that for holding the post of Senior Teacher, a person must be graduate or equivalent examination with the concerned subject and one more subject taught in Class 9th and 10th as Optional Subjects."
Finally, the Court concluded: "In the considered opinion of this Court, nothing has come on record which shows that the B.A. Additional Course conducted by the respondent-University is not recognized, therefore, the B.A. Additional Course conducted by the University is held to be equivalent to the eligibility condition mentioned in Schedule-1 of the Rules of 2008."
The High Court issued the following directives: "Accordingly, the writ petition merit acceptance and the same is allowed."
"The order dated 14.04.2025 is quashed and set aside. The petitioners’ qualification of B.A. Additional Course cannot be held to be a certificate vacation course only."
"The promotions granted to the petitioners on the post of Senior Teacher is just, proper and correct as they are holding the requisite qualification for the post."
"The stay application and other pending applications, if any, also stand disposed of."
Advocates Representing the Parties:
For the Petitioners: Mr. Dheerendra Singh Sodha, Mr. Pankaj Mehta, Mr. Kailash Jangid
For the Respondents: Mr. Vinay Jain, Mr. N.K. Mehta (DyGC), Mr. Darshan Jain, Mr. Vudit Balia, Mr. Devendra Prajapati
Case Title: Ashok Kumar & Ors. vs. State of Rajasthan & Ors.
Neutral Citation: 2025: RJ-JD:32456
Case Number: S.B. Civil Writ Petition No. 8863/2025
Bench: Justice Vinit Kumar Mathur
