M.Ed. is a postgraduate degree, M.Ed. qualified persons can be appointed to the post of Assistant Professor in Education: SC

Anand Yadav & Ors v. State of Uttar Pradesh & Ors

Civil Appeal No. 2850 of 2020 decided on 12.10.2020

Bench:  Sanjay Kishan Kaul, Anirudha Bose, Krishna Murari, JJ.

Facts:

Application were invited for the post of Assistant Professors in various subjects including ‘Education’ by the Uttar Pradesh Higher Education Service Selection Commission (UPHESSC). A corrigendum was issued later by the UPHESSC which mentioned that M.Ed degree can be treated as equivalent degree to M.A. (Education) for the purpose of appointment to the post of Assistant Professor. A writ petition was filed in the High Court by few candidates challenging the corrigendum. The High Court allowed the writ petition, quashed the corrigendum and observed that M.A (Education) is a master’s degree in the subject while M.Ed. is not so, it is only a training qualification. Later a Special Leave Petition and an appeal to the judgement of the High Court was filed in the Supreme Court.

Issue:

Does the degree of M.Ed qualify as a master’s programme in Education? And would the M.Ed degree be treated as an equivalent degree to M.A. (Education) for the purposes of appointment to the post of Assistant Professor?

Held:

The Supreme Court while allowing the appeal held that M.Ed is a postgraduate degree and observed that M.Ed qualifies as a master’s programme in Education and is also recognised by the UGC and NCTE. 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 degrees, it has clearly stated that for the job of Assistant Professors (Education), both M.A (Education) and M.Ed are eligible.

The court also observed that, the fact that both M.Ed. and M.A. (education) degree holders have to take a common test for the purposes of NET is not conclusive but one of the factors to be considered and once the expert body being the NCTE has taken that aspect into consideration apart from other factors to opine the equivalence of the two degrees 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 set aside the High Court judgement and noted that UPHESSC had sought the opinion of the expert panel and then took the decision permitting M.Ed degree as an eligible qualification of appointment. The matters of education must be left to educationists subject to being governed by the relevant statutes and regulations.