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2026 DAILYLAW 10397 (GAU)

State of Nagaland v. Rongsenkangla

2026-03-25

Devashis Baruah, Yarenjungla Longkumer

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JUDGMENT : DEVASHIS BARUAH, J. 1. Heard Ms. V. Suokhrie, the learned Additional Advocate General appearing on behalf of the State of Nagaland and Mr. C.T. Jamir, the learned Senior Counsel assisted by Mr. I. Imchen, the learned counsel who represents the respondents in the present Appeal. 2. The present Writ Appeal is directed against the judgment and order dated 16.02.2026 passed in WP(C) No.246/2023 whereby the learned Single Judge had set aside the Circulars dated 15.03.2023 and 23.03.2023 issued by the Directorate of School Education, Nagaland. 3. The reason for doing so as it appears from the impugned judgment and order is that the Government of Nagaland had issued a Notification on 15.09.2021 whereby the untrained teachers were granted a further opportunity to undergo the required academic qualification and professional training within five years timeframe, i.e. with effect from 2022 to 2027. It was the opinion of the learned Single Judge that prior to the expiry of the said period, the impugned Circulars dated 15.03.2023 and 23.03.2023 ought not to have been issued by the Directorate of School Education, Nagaland, and as such, the said Circulars were interfered with. 4. It appears from the materials on record that the Respondents herein were appointed during the period from 2001 to 2012 and were subsequently regularized to various posts in different Government Middle Schools as Primary Hindi Teachers all over the State of Nagaland. The educational qualifications of the Respondents herein is Class VIII pass and they have undergone training/diploma in Hindi from the Hindi Teachers Training Institute at Dimapur. It is the contention of the Respondents in the writ petition that the course undergone by the Respondents, i.e. Hindi Sikshan Praveen is equivalent to Teacher’s Training Certificate/Diploma as have been acknowledged by the Government of India in its letter dated 25.11.2003. On 04.09.2017, a Press Release was issued whereby the Respondents were directed to undergo Diploma in Elementary Education and it is alleged that the Hindi Teachers who were appointed prior to 03.09.2001 were exempted from undergoing such Diploma in Elementary Education. 5. On 04.09.2017, a Press Release was issued whereby the Respondents were directed to undergo Diploma in Elementary Education and it is alleged that the Hindi Teachers who were appointed prior to 03.09.2001 were exempted from undergoing such Diploma in Elementary Education. 5. It is the further case of the Respondents herein that on 15.09.2021, a Notification was issued by the Principal Director notifying that many in-service Hindi Teachers were found untrained and as per the Finance Department’s directive, all in-service Untrained Graduate and Under- Graduate Hindi Teachers were required to acquire the requisite academic and professional qualification as per the NCTE norms. Under such circumstances, directions were issued that all untrained teachers were to obtain the required academic qualification and professional training within five years timeframe w.e.f. 2022 to 2027 which can be done from the institutions such as NIOS and IGNOU. 6. It is the case of the Respondents that on 15th of March, 2023, the Director of the Directorate of School Education had issued a Circular asking all untrained Hindi Teachers/UGT/GHT serving under the Directorate of School Education, (DSE), Nagaland, Kohima appointed after September, 2001 to submit the following necessary educational qualification documents:- (i) UGGT: Class 10 & 12, both General and Hindi, (ii) GHT: Class 10 up to BA, both General and Hindi to the concerned DEOs/SDEOs on or before 29th of March, 2023 and the DEOs/SDEOs were requested to submit the collected documents along with the formats to the Directorate of School Education (DSE), Room No.510 on or before 6th of April, 2023. 7. Subsequent thereto, the Principal Director, Directorate of School Education issued another Circular on 23rd of August, 2023 whereby all untrained Hindi Teachers (Diploma Certificate Holder) serving under the Directorate of School Education, who were yet to submit their General Qualification Certificates up to Class 12 qualified were reminded to submit the same on or before 26.08.2023 without fail for onward submission to SCERT for D.El.Ed admission for the Session 2023-25. 8. The case of the Respondents herein is that while in terms with the Notification dated 15.09.2021, the Respondents were granted time up to 2027, however, vide the Circulars which were issued on 15.03.2023 and 23.08.2023, steps were taken to reduce the said period thereby asking the Respondents to submit the credentials on or before 26.08.2023. 8. The case of the Respondents herein is that while in terms with the Notification dated 15.09.2021, the Respondents were granted time up to 2027, however, vide the Circulars which were issued on 15.03.2023 and 23.08.2023, steps were taken to reduce the said period thereby asking the Respondents to submit the credentials on or before 26.08.2023. It is under such circumstances, the Respondents herein as Petitioners filed the writ petition challenging the impugned Circulars dated 15.03.2023 and 23.08.2023 9. We have perused the impugned judgment and order passed by the learned Single Judge. The Circulars dated 15.03.2023 and 23.08.2023 were interfered with on the ground that the Circulars were contrary to the Notification dated 15.09.2021 whereby time was granted to all untrained Graduate Hindi Teachers and Under-Graduate Hindi Teachers for a period of five years, i.e. with effect from 2022 to 2027 to obtain the necessary qualification. 10. Being aggrieved by the impugned judgment and order, the present Writ Appeal is filed by the State Government. 11. From the grounds of objection taken in the Memo of Appeal filed by the State of Nagaland, it appears that the challenge made to the impugned judgment and order dated 16.02.2026 is on the ground that the said Circulars ought not to have been interfered with in as much as the Circulars were in the form of reminders to those teachers who did not have the qualification and were appointed after September, 2001 to go ahead with their training. The learned Additional Advocate General submitted that though the Notification dated 15.09.2021 permitted the untrained Graduate and Under-Graduate Hindi Teachers to obtain the necessary qualification within the period from 2022 to 2027, but in absence of these Circulars, there was always a likelihood that these teachers who were underqualified would later on say that they had no knowledge about the Notification dated 15.09.2021. It is under such circumstances, these Circulars were issued. 12. We put a specific query upon the learned Additional Advocate General for the State of Nagaland as to whether the State of Nagaland would deviate from the stand taken in the Notification dated 15.09.2021. The learned Additional Advocate General submitted that it is the very specific stand of the State of Nagaland that all untrained Graduate and Under-Graduate Hindi Teachers would be permitted to acquire the requisite academic and professional qualifications within five years w.e.f. 2022 to 2027. 13. The learned Additional Advocate General submitted that it is the very specific stand of the State of Nagaland that all untrained Graduate and Under-Graduate Hindi Teachers would be permitted to acquire the requisite academic and professional qualifications within five years w.e.f. 2022 to 2027. 13. In view of the above submissions, we find it relevant to take note of the impugned judgment and order dated 16.02.2026, and more particularly, the observations made by the learned Single Judge at paragraph Nos.43, 44 & 45 of the impugned judgment and order. We are of the opinion that as it is the stand of the State of Nagaland that the impugned Circulars dated 15.03.2023 and 23.08.2023 were mere reminders so that the untrained Graduate and Under- Graduate Hindi Teachers shall take appropriate steps for acquiring the academic qualifications within the time permitted by the Notification dated 15.09.2021, the learned Single Judge ought not to have set aside the impugned Circulars. 14. Accordingly, we therefore dispose of the instant Appeal by modifying the impugned judgment and order dated 16.02.2026 passed in WP(C) No.246/2023 to the extent that the said Circulars dated 15.03.2023 and 23.08.2023 need not be set aside, but the Circulars dated 15.03.2023 and 23.08.2023 shall be construed to be mere intimation to all the untrained Graduate and untrained Under-Graduate Hindi Teachers that they are to obtain the educational qualification within the period mentioned in the Notification dated 15.09.2021.