Extracted from the PDF above. The PDF is authoritative.
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IN THE HIGH COURT OF ORISSA AT CUTTACK RVWPET No.92 of 2025
(In the matter of an application under Order 47 read with Sections114 &151 of Civil Procedure Code, 1908)
Jhasketan Sahoo & Ors. …. Petitioner(s) -versus- State of Odisha & Ors. …. Opposite Party (s)
Advocates appeared in this case through Hybrid Arrangement Mode:
For Petitioner(s) : Ms. Adhyasidhi Mishra, Adv.
For Opposite Party(s) : Mr. Sonak Mishra, ASC. Ms. Sephalee Das, Adv.
CORAM:
DR. JUSTICE SANJEEB K PANIGRAHI
DATE OF HEARING:-07.03.2026 DATE OF JUDGMENT: -22.05.2025
Dr. Sanjeeb K Panigrahi, J.
1. In this RVWPET, the Petitioner seeks review of the judgment dated 20.09.2022 passed in W.P.(C) No.29418 of 2021 dismissing his prayer therein for quashing of the selection of the Opposite Party No.5 to 13 therein and others as Assistant Professor in Teacher Education (Geography). 2. The Petitioner now seeks to recall of that decision on the ground that it was rendered without considering the material submissions and the relevant law, resulting an error apparent on the face of the record. 3. For clarity, the operative portion of the aforesaid judgment under review is reproduced below: Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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“29. It is important to note that the NCTE Notification prescribes, minimum qualifications' of teachers. It is not intended to be exhaustive. It is merely a guideline which provides that candidates not possessing the minimum qualification prescribed by it, will not be eligible for appointment as Secondary Teachers. In my considered view, this would not prevent the State Legislatures from prescribing additional or specific criteria which a candidate must meet for being eligible for appointment as Secondary Teacher. This, in my view, is entirely reasonable requirement. After all, unless a candidate is reasonably proficient in speaking, reading and writing in the language which he has chosen as the medium of instruction, he would be unable to communicate with the student ssuccessfully or to effectively discharge his/her role and duties as a teacher. In my considered view, there is no conflict between the NCTE Notification and the Recruitment Notification/Advertisement. Both the NCTE Notification and the Recruitment Rules framed by the Board can stand together. Hence, the said provision in the impugned notification/advertisement cannot be said to be repugnant to the NCTE Notification. 30. The Learned Counsel for the Petitioners submits that a candidate is not estopped from challenging the selection process if the selection process has misconstrued statutory rules as the selection process allegedly has done in the matter at hand. Ld.
Counsels for the Opposite Parties have, on the other side, vehemently argued that the present Writ Petitions are not maintainable given participation of the petitioner that the Petitioner have admittedly participated in the selection process and understood all terms and conditions laid down in the impugned advertisement. 31. In this regard, it is trite in law that a candidate who has participated in the selection process, upon being unsuccessful, cannot turn around and challenge the advertisement. This position of law has been time and again Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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reiterated by Hon’ble Supreme Court in Madal Lal v. State of J.K., Ranjan Kumar v. State of Bihar, Anupal Singh v. State of U.P., Vijay Seyal v. State of Punjab and Dr. G. Sarana v. University of Lucknow. In Dhananjay Malik v. State of Uttaranchal. It has been held by the Hon’ble Supreme Court that having participated in the selection process without any demur, the writ petitioners are estopped from complaining that the selection process was not in accordance with the Rules. If they thought that the advertisement and selection process were not in accordance with the Rules, they should have challenged the advertisement and selection process, at the threshold itself, without participating in the selection process. 32.As it flows therefrom, needless to say that the persons who participated in the selection process after having accepted the terms and conditions of the selection, cannot challenge the said process subsequently and this issue, therefore, is answered in favour of the Opposite Parties. 33. In light of the aforesaid discussion and having regard to the present position of law, this Court has no hesitation in coming to the conclusion that the petitioner cannot be granted any relief by way of a writ and the present Writ Petition is liable to be dismissed.”
I.
FACTUAL MATRIX OF THE CASE:
4.
The brief facts of the case are as follows: (i) Shorn of unnecessary details, the factual matrix of the case, in brief, is that an advertisement was issued by the OPSC on27.07.2021 to fill up the post of Asst. Professor (Teacher Education) Stage-1 in different disciplines in Government Teachers' Training Institutes under the Department of Higher Education of Odisha. Such Advertisement No.09 of 2021-22was issued by the OPSC pursuant to the Government Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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instruction and also the Odisha Education Service (College Branch) Recruitment Rules, 2020. The petitioner after completion of his M.A. (Geography) in the year 2005 from Utkal University joined B.Ed, course under Sambalpur University and passed it in the year 2006. Thereafter, the petitioner was selected for admission to the M.Ed, course under Utkal University and completed M.Ed, in 2008. He has obtained M. Phil in Geography from Utkal University in 2009 followed with NET in 2009 and PhD in Geography in the year 2018. Since the petitioner had the eligibility to be appointed as Asst. Professor, Teacher Education (Geography), has applied in the prescribed from pursuant to the Advertisement. (ii) The NCTE being the Apex Body in teachers’ education and training, has prescribed the required qualification for appointment as Teacher/Asst. Professor in all these two years B.Ed./M.Ed. course in colleges. The relevant extract provided in the 2014 Regulation in its Appendix-4 is quoted as hereunder. "5,2 Qualifications The faculty shall possess the following qualification: A. Principal/HoD (i)Post graduate degree in Arts/Science/Social Science/Humanities/Commerce 55% marks; and with minimum (ii) M.Ed, with minimum 55% marks; and (iii) Ph.D. in Education or in any pedagogic subject offered in the institution; (iv) Eight years of teaching experience in a secondary Teacher Education Institution. Desirable: Diploma/Degree in Educational, Administration or Educational Leadership.
B. Perspectives in Education or Foundation Courses (i) Postgraduate degree in Social Science with minimum 55% marks; and Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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(ii) M.Ed, degree from a recognised university with minimum 55%marks. OR (i) Post graduat (MA)degree in Education with minimum 55% marks and (ii) B.Ed./B.EI.Ed. degree with minimum 55% marks. C. Curriculum and Pedagogic Course. (i) Postgraduate Science/Mathematic/Social degree in Sciences/Languages with minimum 55% and (ii) M.Ed. degree with minimum 55 % marks, Desirable: PhD degree in Education with subject specializations. [Note: In case of B and C put together, for two faculty positions, a postgraduate degree in Sociology/Psychology/Philosophy with 55% marks and B.Ed/ B.EI.Ed with 55% marks and three years of teaching experience in a secondary school shall be considered]”
(iii) Following the NCTE Regulation, the State Government has brought in the Odisha Education Service (College Branch) Rules, 2020 vide Government Notification dated 18.02.2021 under Annexure-1. Rule-6 specifically provides that the qualification for appointment of Asst. Professor should be in consonance with NCTE Regulation 2014, which reads as follows:
"6. Eligibility criteria for Direct Recruitment- In order to beeligible for direct recruitment, a candidate must, (i) be a citizen of India. (ii) not be above 45 years of age as on the last date of receiving application fixed by the Commission: Provided that relaxation in the upper age limit in respect of different categories of candidates referred to in rule 4 shall be made in accordance with relevant Acts, Rules, Resolutions, Notifications or Orders issued by the Government from time to time. (iii) be able to read, write and speak in Odia. (iv) have passed Upper Primary examination, or its equivalent, with Odia as a subject.
(v) Possess a Master's; Degree, or dual Master's degree for the post of Assistant Professor (Teacher Education) if the guidelines Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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of National Council for Teacher Education so demand, with at least 55%of marks its equivalent grade, in the concerned/relevant/allied subject from an Indian University or an equivalent degree from a foreign university:"
(iv) Following the aforesaid guideline/regulation of the NCTE and the Rules-2020, the State Government has sent the requisition to the OPSC to fill up the post of Asst. Professors in Govt. Training Colleges. Accordingly, the OPSC has issued Advertisement No.09 of 2021-22. Caise-4 of the Advertisement deals with the education qualification required for the purpose which reads as thus:
"4. EDUCATIONAL QUALIFICATION: A candidate must: (A) Possess a Master's Degree or dual Master's Degrees for the post of Assistant Professor (Teacher Education), if the guidelines of National Council for Teacher Education so demands, with at least55% of marks or its equivalent grade in the concerned/relevant/allied subject from an Indian University or an equivalent Degree from a Foreign University. Provided that for the candidates belonging to Scheduled Caste, Scheduled Tribe, SEBC & Persons with Disabilities categories, the requirement of securing atleast55% marks shall be to 50% marks or its equivalent grade. B. Have cleared National Eligibility Test (NET) meant for Assistant Professor (Stage-1) or must have acquired a Ph.D. Degree in the concerned/relevant/allied subject from an Indian University or a Foreign University OR NET in Education Or in Ph,D, in Education. C. The details of the essential qualifications for recruitment to the posts of Assistant Professor (Teacher Education)-Stage-I are mentioned at Annexure-A to this advertisement.”
II. PETITIONERS’ SUBMISSIONS:
5.
Learned counsel for the Petitioner(s) earnestly made the following
submissions in support of his contentions: Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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(a) The educational qualification so required as per rules is that one must have dual Master's Degree. This dual master degree is a mandatory requirement under NCTE Regulation, 2014, which is meant for the training colleges wherein two years B.Ed, course and 2 years M.Ed. course are taught. However, M.A. in the concerned subject with B.Ed. training is only required for the institutions wherein 4 years integrated course are imparted. Accordingly, the NCTE has brought in amended to its Regulation of 2014 vide its notification dated 29.03.2019. But in the amendment of Regulation, 2019, only Appendix-16 and 17 have been substituted, but Appendix-4 of the 2014 Regulation which deals with the qualification required for the Asst. Professor to be pointed for these two years B.Ed. and 2 years M.Ed. course have not undergone any amendment or change. In other words, NCTE, knowing fully well regarding the factual position of continuance of 2 years B.Ed, and 2 years M.Ed. course allowed these two sets of regulations with separate eligibility qualification; i.e. NCTE Regulation, 2019. More so, the2014 Regulation is meant for the colleges having two years B.Ed. courses and 2 years M.Ed. courses. The 2019 Regulation is meant for the Institutions imparting 4 years integrated course, which has not yet been borne in the State of Odisha in any Government Colleges. However, so far the personal knowledge of the petitioner is concerned only in Ravenshaw University, the 4 years integrated B.Ed, course in self-financing mode is functioning. These statements of the petitioner are well proved from the Government letter no.19324 dated 11.05.2022 wherein the State Government has clarified that it has only 16 teachers’ education colleges Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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with two years B.Ed. including 5 institution having 2 years M.Ed. course. (b) There was no illegality or irregularity committed by the Petitioners in appearing in the process of selection, because this Hon'ble Court has
directed them to appear without prejudice to their claim and further the entire selection was confining for appointment of Asst. Professor in Govt. Training Colleges, concerning the NOTE Regulation, 2014. But surprisingly by such an illegal appointment, now the persons, who do not have dual Master Degrees, became eligible for selection and in fact they have been selected and such selection is contrary to the prescribed qualifications in the NCTE Regulation, 2014 and in the 2020 Rules. In a harmonious reading of all these provisions together, one thing is clear and unambiguous that the NCTE Regulation is the paramount
consideration for appointment of Teachers in those two years' training Colleges. Since it requires dual Master Degrees, no person with M.A., B.Ed. Degree can be selected or appointed. Hence, the selection of the Opp. Parties No.5 to 13 in those 16 Institutions including 5 M.Ed. Colleges, is per-se illegal. (c) It is further submitted that The Review Petitioners, without prejudice to the above further humbly say and submit that not only Ravenshaw University , in many other Institutions 4 years' B.A./B.Ed., B.Sc./B.Ed. (Appendix-13) have been launched, but not any other Programmes. The recruitment programme as regard the eligibility conditions are bit different. In Appendix -13 for the content programme, no pedagogical degree is essential under NCTE Regulation-214. In Appendix- 15(Regulation-2021) all the three branches, i.e. Science, Arts and Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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Commerce have been notified. In response to the Advertisement of NCTE for ITEP (Regulation-2021) Govt. Agencies have applied and the result is not yet known. Moreover, the ITEP will be launched as a Pilot Programme, where 50 numbers of Institutions in the Country would be given permission to launch it. In Odisha maximum 2-3 Institutions may get chance of having multidisciplinary nature. The Education Institutions do not have scope of instituting such programme and they automatically pharming out from the Session: 2022-23and the B.Ed. Programme is standalone Colleges will continue for some more time. Hence, the Asst. Professor recruited for liberal and pedagogical studies have no role to play in standalone B.Ed. Colleges as the Asst. Professor recruited for Educational studies will be enough to run the programme and B.A./B.Sc. liberal course does not find place in the curriculum. (d) It is further submitted that without the permission of NCTE, Govt. of Odisha is not capable of launching ITEP Programme, which is going to be launched as Pilot study. The NCTE Regulation-2014 and 2019 as regards 4 years' Integrated Programme does not exist anymore after the Academic Session: 2022-23 and even for ITEP from B.Com./B.Ed. there is no indication of recruitment. The Teachers are now recruited for4 years integrated programme ( as stated for NCTE Regulation- 2019). (e) The Regulation -2014 does not hold good as it is notified, there was no appreciation to the facts and implementation of the Regulation -2024 /2019.
It is needless to mention herein this context that in the State of Odisha as of now, there is no 4 years' Integrated B.Ed. Course in any of the Govt. Training Colleges of the State. However, only 2 years' B.Ed, Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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and M.D. Courses are prosecuted in 16 numbers of Training Colleges as per the Govt. of India Notification the 4 years ' Integrated Course are only be implemented from the Session: 2022-23 and for which no affiliation or permission has yet been granted to the NCTE to the State of Odisha. In these peculiar facts and circumstances, issuing the impugned Advertisement to recruit teachers for 4 years' Integrated Course is completely illegal, irrational and arbitrary. This Hon'ble Court in the previous Writ Petition proceeded with the matter on the wrong notion that since the Petitioners have participated in the process of recruitment, they cannot challenge the advertisement. (f) On complete reading of Rule-6 of the Recruitment Rules, 2020 with Clause :5.2 of the NCTE Regulation, 2014, it is unambiguous that the recruitment of Asst. Professor in Teacher Training Colleges, imparting education for 2 years' B.Ed, and 2 years' M.Ed. Course, the Asst. Professor should have PG in the Sciences / Social, which needs with minimum 55% marks and M.Ed. Degree with 55%marks. Besides the above, the desirable qualification in Ph.D. in Education. The State of Odisha is now having 16 numbers of Government Training Colleges imparting for two years B.Ed, including 5 M.Ed. Colleges. Unfortunately, M.Ed, is a P.O. Course and certainly a B.Ed, candidate, which is the Under-Graduate Course cannot teach a student in M.Ed. Course. Therefore, the Advertisement, dated 27.07.2021 under Annexure- 2 and the stipulation made in Asst. Professor in those Institutions is against the rule and also the NCTE Regulation.
There was a slight confusion ,so far as the Petitioners are concerned, while disposing the Writ Petition bearing W.P.(C) No.29418/2021 in a common Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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Order, passed on 27.07.2021 by stating that the Petitioners of that Writ Petitions were participants in the Advertisement, where the Petitioners had never participated in the Advertisement, but in fact they challenged the Advertisement, without being a part of it. (g) This Court has committed error in dismissing the Writ Petition as the impugned judgment has been passed without considering the material
submissions and the discussions of the relevant judgments of the Supreme Court. (h) In such view of the matter, he submitted that the impugned judgment passed by this Court may be reviewed.
III.
SUBMISSIONS OF THE OPPOSITE PARTIES:
6.
Learned counsel for the Opposite Parties earnestly made the following
submissions in support of his contentions: (a) This review petition is not maintainable as this Court has not left any space for reconsideration of the same. (b) Moreover, the said judgment has been passed after considering all the
facts and documents placed before this Court and, accordingly, the said
Judgment is complete from all aspects, which needs no further interference. (c) It is further submitted that the grounds taken in this review petition were all taken by the Petitioner in his Writ Petition and those are also vividly discussed in the judgment passed by this Court. Hence, this review petition is nothing but a frivolous petition consuming the precious time of this Court. Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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(d) It is submitted that the Petitioners participated in the selection process for the post of Asst. Professor Teacher Education (Geography) pursuant to the advertisement No.09 of 2021-2022 issued by the OPSC. The Petitioners who were well aware of the requisite educational qualifications prescribed under the advertisement participated in the selection process for the post of Asst. Professor Teacher Education (Geography) in Education colleges with open eyes but failed to secure a position in the select list of recommended candidates. It is pertinent to note that the qualification prescribed in the aforementioned advertisement issued by the OPSC is quite in sync with the NCTE Regulations 2014 & 2019 and Odisha Education Service (College Branch) Recruitment Rules 2020. (e) The review proceedings are not by way of an appeal and have to be strictly confined to the scope and ambit of Order 47, Rule 1 of the Code of Civil Procedure 1908. In exercise of the jurisdiction under Order 47, Rule 1 of Code of Civil Procedure 1908 it is not permissible for an erroneous decision to be “reheard and corrected”. A review petition, must be remembered, has a limited purpose and cannot be allowed to be an appeal in disguise. Thus, the power of review can be exercised for the correction of a mistake, but not to substitute a view (i.e. the review court does not sit in appeal over its own order and it constitutes an exception to the general rule that once a judgment is signed or pronounced, it should not be altered). (f) The Review Petitioners participated in the process of selection knowing fully well that the educational qualification was clearly indicated in the advertisement itself.
So instead of challenging the Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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Advertisement/Recruitment process at the threshold, the petitioners participated in the recruitment process and after being unsuccessful, challenged the recruitment process for the post of Assistant Professor (Teacher Education) on the ground that selected candidates do not possess dual postgraduate degree (M.A. + M.Ed.) as required under NCTE Regulations. (g) In this regard, the Supreme Court inChandra Prakash Tiwari and Others vs. Shakuntala Shukla and Others1held that “When a candidate appears at an examination without objection and is subsequently found to not successful, a petition challenging the said process stand barred.: (h) In University Grants Commission and Another vs. Neha Anil Bobde Gadekar2, the Supreme Court held that; Educational policy, academic qualifications and recruitment norms fall within the exclusive domain of expert regulatory bodies and the executive. Recruitment decisions cannot be interfered by Courts unless there is manifest illegality or arbitrariness.” (i) In Malleeswari vs. K. Suguna and Another3, the apex court has held that; “A review petition has a limited purpose and cannot be allowed to be an appeal in disguise. In exercise of the jurisdiction under Order 47 Rule 1 of CPC, it is not permissible for an erroneous decision to be reheard and corrected. (j) In such circumstances, he contends that the review petition being devoid of merit, is liable to be dismissed. IV. COURT’S REASONING AND ANALYSIS:
7.
Upon hearing learned counsel for the parties and upon careful perusal of the materials available on record, this Court finds that the principal
1 (2002)6SCC 127 2 (2013) 10 SCC 519 3 2025 SCC Online SC 1927 Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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question arising for consideration in the present review petition is not the correctness of the conclusions reached in the judgment under review as if sitting in appeal over the same, but whether the said
judgment suffers from any error apparent on the face of the record warranting exercise of review jurisdiction under Order XLVII Rule-1 of the Code of Civil Procedure. The contours of review jurisdiction are by now too well settled to admit of any ambiguity. 8. A review proceeding cannot be converted into a rehearing of the matter on merits merely because another view is possible. Unless there exists a patent error, manifest illegality, or omission of a material statutory provision resulting in miscarriage of justice, the finality attached to judicial pronouncements cannot be lightly disturbed. The power of review is therefore an exception to the doctrine of finality of litigation and must necessarily be exercised within narrowly defined limits. 9. In the case at hand, the Review Petitioners essentially seek reconsideration of the very issues which had already fallen for adjudication in the writ proceedings. The core contention advanced by the Petitioners is that under the NCTE Regulations, 2014, possession of dual postgraduate qualifications, namely Postgraduate Degree in the concerned subject together with M.Ed., constituted an indispensable eligibility condition for appointment as Assistant Professor in Teacher Education institutions imparting two-year B.Ed. and M.Ed. programmes, and consequently the candidates selected pursuant to Advertisement No.09 of 2021-22, allegedly not possessing such dual qualifications, were ineligible. According to the Petitioners, this Court while deciding the writ petition failed to appreciate the distinction Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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between institutions imparting two-year B.Ed./M.Ed. programmes and institutions imparting four-year integrated programmes contemplated under subsequent NCTE Regulations. 10. However, a careful reading of the judgment under review reveals that the issue regarding interplay between the NCTE Regulations, the Odisha Education Service (College Branch) Recruitment Rules, 2020 and the recruitment advertisement was consciously examined by this Court. The judgment had specifically recorded a finding that the NCTE Regulations prescribe only minimum qualifications and do not operate as a complete embargo against the State or recruiting authority prescribing additional or alternative criteria consistent with the object of recruitment. This Court had further held that there existed no irreconcilable conflict between the NCTE Regulations and the impugned recruitment notification and that both could co-exist harmoniously.
Therefore, the submission now advanced by the Review Petitioners is essentially directed towards persuading this Court to take a different interpretative view of the same provisions which had already been interpreted earlier. Such an exercise unmistakably falls within the realm of appellate scrutiny and not review jurisdiction. 11. It is equally significant that the Petitioners had admittedly participated in the recruitment process pursuant to the advertisement in question. The doctrine that a candidate who consciously participates in a selection process with full knowledge of the governing conditions cannot subsequently assail the same after being unsuccessful is founded upon principles of acquiescence, waiver, and estoppel. Such doctrine is not a mere technical rule but flows from broader equitable considerations Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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intended to preserve certainty and sanctity in public recruitment processes. The judgment under review had extensively relied upon settled precedents of the Hon’ble Supreme Court holding that candidates who take calculated chances in a selection process cannot later challenge the very process after declaration of results. 12. The Petitioners now attempt to contend that they had participated
“without prejudice” or under interim protection of this Court. However, such submissions neither dilute the legal consequences of participation nor create any apparent error in the reasoning already adopted by this Court. At best, the same amounts to reiteration of
arguments previously urged and considered.
13. The attempt of the Petitioners to distinguish between standalone teacher training institutions and proposed integrated teacher education programmes also does not persuade this Court to exercise review jurisdiction. Whether the State presently had institutions imparting four-year integrated programmes or whether the recruitment was intended for future academic requirements were all matters touching upon policy considerations and interpretation of recruitment norms. Once this Court has consciously interpreted the governing regulations and upheld the recruitment notification as not being inconsistent with the statutory framework, the same cannot be reopened in review merely because another interpretation is sought to be projected as more plausible. Review jurisdiction does not permit substitution of one possible view by another.
14. This Court further finds considerable force in the submission advanced on behalf of the Opposite Parties that the present review petition Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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substantially seeks rehearing of the writ petition under the guise of review. The grounds taken herein are virtually a reproduction of the
submissions canvassed in the original writ proceedings. The Petitioners have not been able to demonstrate any patent omission of a binding statutory provision, ignorance of any binding precedent, or any manifest error self-evident from the record. What is sought is a fresh adjudication on merits by re-appreciation of the same factual and legal
contentions, which is wholly impermissible within the limited scope of review jurisdiction.
15. The law is well settled that an error which has to be detected through a process of elaborate reasoning or by undertaking a fresh examination of rival interpretations cannot be treated as an “error apparent on the face of the record.” A review court cannot assume the role of an appellate court to correct what may possibly be perceived as an erroneous decision on merits. Unless the error is manifest, obvious and self-evident, the power of review cannot be invoked. In the considered opinion of this Court, no such manifest error has been demonstrated by the Petitioners in the present case.
16. Moreover, judicial discipline demands that finality attached to judgments should not be unsettled except for compelling and legally sustainable reasons. Endless reopening of concluded adjudications on the basis of repeated interpretative disputes would strike at the very foundation of certainty in judicial administration. The review jurisdiction, therefore, must remain confined to correction of patent errors and cannot become an avenue for dissatisfied litigants to secure a second round of adjudication. Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 27-May-2026 15:45:01 Signature Not Verified
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V. CONCLUSION:
17. Based on this analysis, this Court is of the considered opinion that the Petitioners have failed to make out any ground warranting interference in exercise of review jurisdiction. The judgment dated 20.09.2022 passed in W.P.(C) No.29418 of 2021 which is under review does not suffer from any error apparent on the face of the record requiring reconsideration.
18. The review petition being devoid of merit, accordingly, stands dismissed.
19. Interim order, if any, passed earlier stands vacated.
(Dr. Sanjeeb K Panigrahi)
Judge
Orissa High Court, Cuttack, Dated the 22nd May, 2026