The Madhya Pradesh High Court recently delivered a significant judgment concerning the interpretation of regulatory texts in the context of teacher recruitment. The case centered on a woman candidate who was denied appointment as a Middle School Teacher due to her not meeting the stipulated academic qualifications as per the Hindi version of the National Council for Teacher Education (NCTE) regulations. The core issue revolved around the discrepancy between the English and Hindi versions of the NCTE (Recognition Norms and Procedure) Regulations, 2014.
Justice Subodh Abhyankar, presiding over the case, emphasized the constitutional mandate under Article 348(1)(b)(iii), which asserts that the authoritative text of all laws and regulations enacted by the Parliament or State Legislature shall be in English. This provision played a pivotal role in the court's reasoning, leading to the conclusion that in instances of inconsistency between language versions, the English text must prevail.
The petitioner had participated in the Middle School Teaching Eligibility Test in 2018. Upon the declaration of results, it was determined that she did not meet the eligibility criteria solely because she lacked 50% marks in her bachelor's degree. The state education department, relying on the Hindi version of the 2014 NCTE regulations, had stipulated that a candidate must possess a B.Ed. degree with at least 50% marks in graduation. However, the English version of the same regulation stated that eligibility could be established with 50% marks in either a bachelor's or master's degree in the relevant subject.
The court scrutinized the divergent interpretations presented by the two versions. It observed that the Hindi translation's restrictive criteria unjustly excluded candidates who, like the petitioner, held a master's degree with the requisite marks. The English version's broader criteria, allowing for either bachelor's or master's qualifications, were deemed more inclusive and aligned with the regulation's intent.
In its judgment, the court criticized the respondents for relying solely on the Hindi version without considering the authoritative English text. It highlighted that such an approach not only contravenes constitutional provisions but also leads to unjust outcomes for candidates. The court's decision underscores the importance of adhering to the authoritative language of legal texts to ensure fairness and uniformity in their application.
Consequently, the High Court directed the state education department to appoint the petitioner as a Middle School Teacher, recognizing her eligibility based on her master's degree qualifications. This ruling sets a precedent for future cases where discrepancies between language versions of regulations may arise, reaffirming the primacy of the English text in legal interpretations.
The judgment also serves as a reminder to administrative bodies to exercise diligence in interpreting regulatory provisions, ensuring that candidates are assessed based on accurate and authoritative criteria. By upholding the English version of the NCTE regulations, the court has reinforced the principle of legal certainty and the necessity of uniform standards in public service recruitment processes.
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