Bilaspur High Court: The Bilaspur Bench of the Chhattisgarh High Court has dealt a major blow to 75 Headmasters. The Court dismissed a petition seeking two advance increments based on the acquisition of educational qualifications—such as B.Ed. and D.El.Ed.—at their own expense. This matter concerned Headmasters working in Sarangarh, Raigarh, and surrounding areas.
While hearing the case, Justice Sanjay K. Agrawal observed that the High Court had already delivered a verdict on this very issue. That decision was upheld by a Division Bench of the High Court, and the Supreme Court subsequently declined to interfere with it. Consequently, there are no grounds to entertain a new claim that contradicts the established legal position.
Recruitment rules changed after June 16, 1993
The root of the matter lies in the changes made to teacher recruitment rules on June 16, 1993. Following this amendment, educational qualifications such as B.Ed., D.El.Ed., and BTI became mandatory for appointment to the post of teacher; prior to this, possessing these qualifications was not a compulsory condition for appointment. Recognizing this distinction, the government had formulated a policy to grant two advance increments to eligible teachers who had acquired the necessary educational qualifications at their own expense. The objective was to benefit those teachers who had obtained these qualifications independently.
Challenge to the order dated November 22, 2019
The 75 Headmasters had challenged an order issued on November 22, 2019, which deemed them ineligible for the two advance increments. The petitioners argued that since they had acquired qualifications like B.Ed. and D.El.Ed. at their own expense, they should be granted the benefit of two advance increments in return. They sought relief on these grounds. However, the State Government opposed their claim, citing previous judicial rulings on the subject. Reference Made to the ‘Neelam Dubey’ Case
Representing the state government, a law officer from the Advocate General’s office informed the court that a verdict had already been delivered on this very issue in the case of ‘Neelam Dubey vs. Government of Chhattisgarh’. In that case, a single bench of the High Court had dismissed the petition on April 25, 2024. Subsequently, the petitioner failed to secure relief even in the writ appeal filed against that decision.
The Division Bench of the High Court dismissed the writ appeal on August 9, 2024. The matter then reached the Supreme Court. The Special Leave Petition (SLP) filed in the Supreme Court was also declined for intervention on July 2, 2025.
High Court Relies on Previous Rulings
During the hearing of the current case, the High Court cited all these earlier judgments. The Court observed that since a judicial decision had already been rendered on this legal question—and upheld even after being challenged at a higher level—there were no grounds to reach a different conclusion on the same issue. The Court also attached significance to the amendment made to recruitment rules on June 16, 1993. Following this amendment, qualifications such as B.Ed., D.El.Ed., and B.T.I. became mandatory for appointment to the post of teacher.
No Additional Benefit for Mandatory Appointment Qualifications
The High Court clarified that for candidates appointed as teachers after June 16, 1993, the relevant educational qualifications had become a mandatory condition for appointment. Consequently, a claim for two advance increments could not be made simply on the grounds of acquiring those same mandatory qualifications at one’s own expense after appointment. On this basis, the Court refused to grant relief to the 75 Headmasters who had filed the petition.
Petition of 75 Headmasters Dismissed
Taking into account all facts and previous judicial rulings, the Bilaspur High Court dismissed the petition filed by the 75 Headmasters on August 18, 2026. Thus, the demand for two advance increments based on the acquisition of mandatory qualifications—such as B.Ed. and D.El.Ed.—at their own expense was rejected.
