The Calcutta High Court declined to extend the application deadline for the 2025 Teacher Eligibility Test (TET) for a petitioner whose chance to apply had lapsed, distinguishing the facts from an earlier order that permitted a last-minute off-line application. The decision upholds the authority of statutory deadlines and clarifies that prior extensions granted in exceptional circumstances do not create a general precedent for subsequent cases. This ruling retains binding force for future recruitment and selection disputes involving lapsed deadlines in West Bengal’s education sector.
Summary
| Category | Data |
|---|---|
| Case Name | WPA/23372/2025 of ABHIK CHAKRABORTY Vs STATE OF WEST BENGAL AND ORS. |
| CNR | WBCHCA0467002025 |
| Date of Registration | 22-09-2025 |
| Decision Date | 24-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE JUSTICE SAUGATA BHATTACHARYYA |
| Court | Calcutta High Court |
| Bench | Court No. 18 |
| Precedent Value | Binding within the Calcutta High Court on the issue of application deadline extensions for statutory recruitments |
| Overrules / Affirms | Affirms existing position regarding strict adherence to statutory deadlines |
| Type of Law | Education service law — recruitment and selection procedure; administrative law |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that once the statutory deadline for submitting applications has lapsed, and no exceptional circumstance exists (unlike the facts of an earlier case where intervention occurred on the last application day), a writ court cannot extend the deadline or grant similar relief based on the principle of parity. The authority of a prior order allowing a late application in unique, contemporaneous circumstances does not automatically mandate relief in all similar subsequent petitions. The recruitment body’s notification fixing firm deadlines binds all candidates and must be uniformly enforced. The petitioner’s failure to act within the prescribed period precludes judicial intervention after expiry. |
| Judgments Relied Upon | WPA 22876 of 2025 (Soumen Bag & Ors. v. State of West Bengal & Ors.) |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Relied upon the express terms of the recruitment notification (21 August 2025), which set the application deadline at 24 September 2025, and the factual distinction from WPA 22876/2025, where the writ was moved on the last day, allowing a limited extension for those specific petitioners. |
| Facts as Summarised by the Court | The petitioner, pursuing D.El.Ed. (Special Education), sought permission to apply for TET 2025 after missing the deadline, invoking parity with an earlier court order that granted last-moment relief to another group. The TET application window closed at 5 PM on 24 September 2025. The petition was filed before the deadline expired, but arguments and hearing came after, by which time the deadline had lapsed. The Commission opposed, stressing that the prior case was unique and tied to timely court intervention. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in West Bengal for matters involving administrative deadlines in statutory selections/recruitments |
| Persuasive For | Other High Courts and quasi-judicial authorities across India where similar statutory deadlines are governed by specific notifications |
| Follows | WPA 22876 of 2025 (Soumen Bag & Ors. v. State of West Bengal & Ors.) – but distinguishes on facts |
What’s New / What Lawyers Should Note
- The High Court underscored that extensions or relaxations of statutory deadlines granted in particular instances do not create a general right to similar relief for all subsequently situated candidates.
- Demonstrates a strict approach to adherence to recruitment deadlines — parity is not available unless circumstances are identical and relief is contemporaneously sought.
- Lawyers should advise clients that filing a writ petition after a deadline has expired is unlikely to yield favorable judicial intervention absent extraordinary circumstances.
- Previous judicial indulgence on deadlines should not be relied upon as precedent unless the factual context exactly matches.
Summary of Legal Reasoning
- The Court analyzed the notification dated 21 August 2025, which unequivocally fixed the last date for TET 2025 applications as 24 September 2025, 5 PM.
- The petitioner sought parity based on a prior order (WPA 22876/2025) where the Court had allowed a short extension for applicants who approached the Court on the last day itself and where urgent indulgence was granted due to timing.
- The Commission opposed, highlighting the prior intervention’s special factual context and the finality of the statutory deadline.
- The Court agreed with the Commission, distinguishing the present case from the precedent on the ground that the petitioner did not approach for urgent relief before expiry and significant time had lapsed since the closing date.
- Having found that the recruitment body’s administrative authority and the rigor of the public notice fixed a clear and binding deadline, the Court held that the prayer for extension after the deadline had expired could not be granted.
- Relief previously granted under urgent and unique circumstances does not automatically warrant extension for other, similarly placed, but belated applicants.
Arguments by the Parties
Petitioner
- The petitioner is pursuing training qualifying him for TET, 2025.
- Relied on earlier High Court order extending deadline for similarly situated candidates.
- Sought a similar extension in parity with those previously permitted to apply after the deadline.
Respondent (Commission)
- The application deadline, per notification, was strictly 24 September 2025.
- The earlier writ was moved on the last application day; extension was granted only for those petitioners, not as a general precedent.
- No further extensions should be allowed after the statutory last date, particularly where time has already expired.
Factual Background
The petitioner is a trainee in a recognized special education course and wished to apply for the TET 2025 and State Selection Test for recruitment of Special Education Teachers in government-aided and sponsored schools. The application deadline, as per the official notification, expired at 5 PM on 24 September 2025. While the petitioner filed the writ before closure, the matter was not heard until after the expiry. The petitioner sought similar relief to candidates in an earlier case who received an extension when moving the court on the last possible day.
Statutory Analysis
The judgment referred to the statutory notification issued by the West Bengal Central School Service Commission, which set a strict deadline for application submission and fee payment (24 September 2025 by 5 PM). The Court did not interpret or expand this notification, reaffirming its binding and uniform applicability. No constitutional or other statutory provisions were expressly interpreted or altered.
Alert Indicators
- ✔ Precedent Followed – The Court upheld existing law and procedure regarding adherence to statutory deadlines in recruitment processes, and clarified the limits of judicial extension in exceptional cases.