Unrecognised teacher education institutions cannot seek relief through misrepresentation, and admissions made without statutory recognition cannot be regularised.

Recognition under the National Council for Teacher Education Act and the 2007 Regulations was a statutory precondition for conducting the D.Ed. course, and institutions that misrepresented their recognised status were denied discretionary relief because they had secured interim orders by suppressing material facts. The Court also held that admissions made by unrecognised institutions could not be regularised, as Section 17-A and Regulation 8(12) barred student admissions without recognition. Validation of such admissions would undermine the statutory scheme and public interest, even if the students were not personally responsible for the misrepresentation.

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Issues: (i) Whether institutions that had not obtained recognition under the National Council for Teacher Education Act, 1993 and the 2007 Regulations could maintain a claim to relief after making statements about their recognised status; (ii) Whether admissions made to the D.Ed. course by such unrecognised institutions could be regularised.

Issue (i): Whether institutions that had not obtained recognition under the National Council for Teacher Education Act, 1993 and the 2007 Regulations could maintain a claim to relief after making false statements about their recognised status.

Analysis: Recognition under Section 14 of the Act and compliance with the 2007 Regulations were the statutory preconditions for conducting the teacher education course. The appellants had not been granted recognition, yet they represented that they had been duly recognised and thereby secured interim orders. The Court held that such misrepresentation and suppression of material facts disentitled them to discretionary relief under Article 136 of the Constitution of India.

Conclusion: The appellants were not entitled to relief.

Issue (ii): Whether admissions made to the D.Ed. course by such unrecognised institutions could be regularised.

Analysis: In the absence of recognition, Section 17-A of the Act and Regulation 8(12) prohibited admission of students. The Court held that granting legitimacy to admissions secured through manipulation of the judicial process would defeat the statutory scheme and public interest. The fact that students may not have been personally responsible for the appellants' misrepresentation did not justify validation of admissions made in contravention of the Act and the Regulations.

Conclusion: The admissions could not be regularised.

Final Conclusion: The statutory bar against unrecognised institutions admitting students was enforced, the appeals failed, and the admissions made on the strength of interim orders were denied legal validity.

Ratio Decidendi: A litigant who secures relief by misrepresentation or suppression of material facts is not entitled to discretionary relief, and admissions made by an institution without statutory recognition cannot be regularised in derogation of the governing enactment and regulations.

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