STATE OF NAGALAND AND 2 ORS v. SMTI. RONGSENKANGLA AND 77 ORS
WA/8/2026 · 2026-03-24
Devashis Baruah, Yarenjungla Longkumer
body2026
DailyLaw.ai
[ 2026 DAILYLAW 2932 (GAU) · dailylaw.ai ]
DailyLaw.ai
[ 2026 DAILYLAW 2932 (GAU) · dailylaw.ai ]
Judgment text
Extracted from the PDF above. The PDF is authoritative.
Page No.# 1/15 GAHC020001442026 2026:GAU-NL:186-DB
THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH) KOHIMA BENCH Case No.: WA/8/2026 STATE OF NAGALAND AND 2 ORS REPRESENTED BY THE CHIEF SECRETARY TO THE GOVT. OF NAGALAND 2: THE COMMISSIONER AND SECRETARY DEPARTMENT OF SCHOOL EDUCATION NAGALAND KOHIMA 3: THE PRINCIPAL DIRECTOR DIRECTORATE OF SCHOOL EDUCATION NAGALAND KOHIMA VERSUS SMTI. RONGSENKANGLA AND 77 ORS LOWER AGRI COLONY KOHIMA NAGALAND 2:KHEKIHO YEPTHO HOISHE SATAKHA ZUNHEBOTO 3:SENNILO NMESEN EHUNNU VILLAGE TSEMINYU 4:SMTI. PAUSUI NEWMAI NTU VILLAGE PEREN 5:SMTI RANGWAM ZELIANG
Page No.# 2/15 JALUKIE COLONY WARD - 9 6:KHRUNEZO SWURO SEKRUZU TOWN CHOZUBA 7:SHRI KEVILETUO KEYHO TOULAZUMA VILLAGE CHUMUKEDIMA 8:SMTI. KENYULE LORIN LOWER KENUOZU HILL KOHIMA 9:LONYULE SEMP TSEMINYU OLD TOWN WARD 10:SMTI. HENELO KATH POLICE COMPLEX CHUMUKEDIMA 11:SHRI. LIMATEMSU AONOK CHANGKI VILLAGE MOKOKCHUNG 12:SHRI. O. ECHANTHUNG LOTHA E. KHEL WOKHA VILLAGE WOKHA 13:SMTI. ATHONLE SEB TSEMINYU TOWN 14:SMTI. LEMENO NAGI KUDA VILLAGE A-KHEL 15:SHRI TONYUSIE HOSHOURY LEPHORI VILLAGE PHEK 16:SHRI HETOHO KHETOI VILLAGE AGHUNATO ZUNHEBOTO 17:SMTI. KHRIEVONUO NAKHRO E. KHEL WOKHA VILLAGE
Page No.# 3/15 WOKHA 18:SHRI MARIUS SHITIRI LAKHUTI VILLAGE WOKHA NAGALAND 19:SHRI MHONTHUNG LOTHA TSUMANG B. WOKHA NAGALAND 20:SHRI IMKONGMEREN NEW MINISTERS HILL KOHIMA 21:SMTI. HENGWALE THYUG NEW TEROGVUNYU VILLAGE TSEMINYU 22:SMTI. IMNATOLA CHANGKI VILLAGE MOKOKCHUNG 23:SHRI. SUPENTHUNG MURRY WOKHA VILLAGE 24:SMTI. ZAKIESANUO ANGAMI NERHE MODEL VILLAGE 25:SMIT. THEJANUO ANGAMI GHS THETSUMI PHEK 26:SMTI. VEKUTI-U NUH GPS LEANGNYU VILLAGE MON 27:SHRI TOKAVI SEMA MISHIKITO VILLAGE DIMAPUR 28:SHRI SULTO CHAYA GMS K. KHEL VISWEMA 29:SMTI. K. CHONDANO LOTHA SHAKI VILLAGE WOKHA
Page No.# 4/15 30:SHRI M. TSABEMO NGULLIE SUNGRO TOWN WOKHA NAGALAND 31:SMTI. IMTITULA IMPUR MOKOKCHUNG 32:SHRI TENUCHUBA JAMIR NEW IMPAI VILLAGE PEREN 33:SMTI. T. MERENLEMLA LAKHUNI VILLAGE MOKOKCHUNG 34:SHRI S. IMSUJUNGBA PHOM YAONGYIMCHEN VILLAGE 35:SHRI. P. BOMTHAI TAMLU VILLAGE LONGLENG 36:SHRI IMTINGANGIN ZUXUSHE VILLAGE 37:P. TEMSUPOKLA LONGKUMER LOWER FOREST COLONY KOHIMA 38:M. NGAMNON KONYAK MON TOWN 39:SMTI. KHITILE JEMU TESOPHENYU VILLAGE TSEMINYU 40:W. YEMNYIE PHOM YONGSHE VILLAGE LONGLENG 41:SMTI. NCHUMBENI TSOPOE MEKIRANG VILLAGE WOKHA 42:SMTI. NUKSHILA SANGTAM SUHOI VILLAGE
Page No.# 5/15 NUILANG 43:SMTI. TOHELI AKUHAITO ZUNHEBOTO 44:SMTI. KENYSINLE MAGH UPPER MIDLAND KOHIMA 45:SHRI. B. WANGLEN PHOM TAMLU VILLAGE LONGLENG. 46:SMTI. MHALEVINUO SUOKHRIE MERIEMA VILLAGE KOHIMA 47:SMTI. KISHELI JEKHA KRAMSA VILLAGE DIMAPUR 48:SMTI. CHUBATULA LONGKONGMENDANG WARD TULI MOKOKCHUNG 49:SMTI. KESHELENO ANGELINE TULI MOKOKCHUNG 50:SMTI. MEDOSANUO LHOUSA MEZOMA VILLAGE KOHIMA 51:SMTI. SOYHENLE KENT UPPER CHANDMARI KOHIMA 52:SMTI. NEVUTALU TETSEO ZANI VILLAGE 53:SHRI SENTIZULU PONGEN CHANGKI VILLAGE MOKOKCHUNG 54:SHRI.
MESHENTI MAGH C. KHEL
Page No.# 6/15 KUDA VILLAGE DIMAPUR 55:IMTIMANGYANG AO CHUCHUYIMPANG VILLAGE MOKOKCHUNG 56:SMTI. REMENJUNGLA MOLOUM VILLAGE MEDZIPHEMA 57:SHRI SENTILO SEMY NSUNYU VILLAGE TSEMINYU 58:SHRI VIHOTO K. SUMI L. KHEL DIPHUPAR 59:SMTI. ROKUOSIENUO NEW MARKET KOHIMA 60:SHRI. NEI-U ANGAMI CHIECHAMA VILLAGE KOHIMA 61:SMTI. L. ALOVIN SUMI TOBU MON 62:SMTI. AIENLA AO OFFICER HILL KOHIMA 63:SMTI. MEYINUNGLA PENLI WARD MOKOKCHUNG 64:SHRI DIETHOSE-U MEZOMA VILLAGE KOHIMA 65:SHRI ISAAC LOTHA PANGTI VILLAGE WOKHA 66:SHRI ELUTHIYI RUHO
Page No.# 7/15 PFUSACHODU 67:SHRI LONGVAI PHOM LONGLENG NAGALAND 68:SHRI. KETHOSILIE SEKHOSE KOHIMA VILLAGE KOHIMA 69:SHRI THUNGDEMO TSOPOE GHSS SUNGRO WOKHA 70:SHRI KEVIABEI RUPREO CHIECHAMA VILLAGE KOHIMA 71:SMTI. K. BICHANO KITHAN GMS HUMTSO WOKHA TOWN 72:SHRI. L. MONGCHON KHIAM GMS NEW PANGSHA NOKLAK 73:SHRI T. LANGPE PHOM YONGAM VILLAGE LONGLENG 74:SMTI. KIRENTITLA IMKONGLENDEN COLONY DIMAPUR 75:SMTI. T. LENTILA AO MOLUNGYIMSEN VILLAGE 76:SMTI. WATILA AO AONOKPUYIMSEN MOKOKCHUNG 77:SMTI. E. LOCHUMI KIKON WAKCHUNG MON 78:SHRI. KEDUTSOLHOU VENUH
Page No.# 8/15 PHEK TOWN PHEK
BEFORE HON’BLE MR. JUSTICE DEVASHIS BARUAH HON’BLE MRS. JUSTICE YARENJUNGLA LONGKUMER
For the Appellant(s) : Ms. V. Suokhrie, AAG, Nagaland
For the Respondent(s) : Mr. C. T. Jamir, Senior Advocate Mr. I. Imchen, Advocate Date on which judgment is reserved : NA
Date of pronouncement of judgment : 25.03.2026
Whether the pronouncement is of the Operative part of the judgment? : NA
Whether the full judgment has been Pronounced? : Yes
JUDGMENT AND ORDER (ORAL)
(D. Baruah, J.) 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
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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
Page No.# 10/15 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. 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
Page No.# 11/15 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.e.:- (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
Page No.# 12/15 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. 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,
Page No.# 13/15 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
Page No.# 14/15 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
Page No.# 15/15 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. JUDGE JUDGE Comparing Assistant