Minority institution autonomy protects termination of teacher without prior approval where minority status was already accepted.

A minority institution established and administered by the Jain community falls within Article 30(1), and on that basis the governing rules did not require prior approval before terminating a teacher's service. A prior Division Bench ruling recognising the institution's minority status was binding on the Single Judge, so a contrary view could not be sustained. State authorities also could not treat the same institution inconsistently after accepting that status. The termination was therefore legally valid.

---

---

Issues: Whether the appellant institution, being a minority institution, could terminate the services of a teacher without prior approval of the District Basic Education Officer, and whether the High Court could ignore an earlier Division Bench decision recognising the institution's minority status.

Analysis: The institution had earlier been treated as a minority institution established and administered by the Jain community, which is a religious minority for the purpose of Article 30(1) of the Constitution of India. On that footing, the governing rules did not require prior approval before termination of a teacher's service. The earlier Division Bench decision on the same issue was binding on the learned Single Judge, and the subsequent contrary view could not be sustained. The State authorities also could not deal with the same institution inconsistently after having accepted its minority status.

Conclusion: The termination did not require prior approval and the appellant's action was legally valid; the contrary view of the High Court was unsustainable.

---