Matters Of Education Must Be Left To Educationists: SC Holds M.Ed Is A Postgraduate Degree [Read Judgment]

Matters of education must be left to educationists, observed the Supreme Court while setting aside an Allahabad High Court judgment which held that an M.Ed. qualified person could not be appointed to the post of Assistant Professor in Education.

A three judge bench held that the M.Ed. degree is a postgraduate degree.

Uttar Pradesh Higher Education Service Selection Commission invited applications for the post of Assistant Professors in various subjects, including 'Education'. Later, the UPHESSC issued a corrigendum which clarified that M.Ed. Degree can be treated as an equivalent degree to M.A. (Education) for the purposes of appointment to the post of Assistant Professor. The High Court, allowing the writ petition filed by a few candidates, quashed the corrigendum and observed that while M.A. (Education) is a master's degree in the subject concerned, M.Ed. is not so, as it is only a training qualification.

In appeal, the bench comprising Justices Sanjay Kishan Kaul, Aniruddha Bose and Krishna Murari noted that M.Ed. qualifies itself as a master's programme in Education and is even recognised by the UGC and NCTE as such. The Court said:

"There is no doubt about the M.Ed. degree being a post graduate degree, in view of not only what the UGC stated before us, but having promulgated the relevant Regulations as far back as 2010 as amended from time to time. The issue of equivalence has been rightly considered by the NCTE and while recognising some distinct aspects of two the degrees, it has clearly stated that for the job of Assistant Professors (Education), both are eligible."

The court, however, clarified that it is not as if a person with an M.Ed. degree is eligible for all the posts which were advertised for Science, Arts and others. The court said:

"Their eligibility has been found only for the post of Assistant Professor (Education), which is directly relatable to the subject to be taught. We do not think the fact that both M.Ed. and M.A. (Education) degree-holders have to take a common test for the purposes of NET is conclusive, but it is one of the factors to be considered, and once the expert body being the NCTE, inter alia, has taken that aspect into consideration apart from other factors to opine equivalence for the purpose of appointment to the post of Assistant Professor in Education, it would not be appropriate to take a contra view."

The court noted that UPHESSC had sought the opinion of the expert panel, and thereafter took a decision, permitting M.Ed. degree as an eligible qualification for appointment. While setting aside the High Court judgment, the bench further remarked:

"We say so in view of the fact that matters of education must be left to educationists, of course subject to being governed by the relevant statutes and regulations. It is not the function of this Court to sit as an expert body over the decision of the experts, especially when the experts are all eminent people as apparent from the names as set out. This aspect has received judicial imprimatur even earlier and it is not that we are saying something new."

Case name: ANAND YADAV vs. STATE OF UTTAR PRADESH

Case no. : CIVIL APPEAL NO. 2850 OF 2020 

Coram: Justices Sanjay Kishan Kaul, Aniruddha Bose and Krishna Murari

Counsel: Sr. Adv P.S. Patwalia and Sr. Adv Meenakshi Arora

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