3-Yrs BPE Degree Equivalent To B.P. Ed For Physical Training Instructor, Rejection Based On Short-Form 'BPE' Is Misnomer: Rajasthan High Court

The Rajasthan High Court has held that the 3 year degree of Bachelor of Physical Education (“BPE”) could not be differentiated from the one year decree of Bachelor of Physical Education (B.P.Ed), and the candidate possessing BPE was eligible to be appointed as Physical Training Instructor (“PTI”) Grade III.

The division bench of Acting Chief Justice Sanjeev Prakash Sharma and Justice Maneesh Sharma held that the word “B.P.E” was only to denote the course of three years, and in no other way could it be differentiated from BPEd which was only of one year. A course which was of greater duration could not be said to be lesser qualification than that of a course of one year.

The Court was hearing a special appeal filed by a bunch of candidates who had participated in the recruitment process for PTI, and were holders of BPE. The challenge was against the non-consideration of appellants for appointment which required educational qualification of BPEd.

National Counsel for Teacher Education (NCTE) was impleaded as a party which stated that NCTE granted recognition to the degree of BPE and it was also a professional qualification making the concerned person eligible for the post of PTI.

In this background, the Court observed that a person having qualification of BPE was eligible to be appointed on the post of PTI since such qualification was recognised by NCTE as same as that of BPEd.

“In the circumstances, we hold that a person who possesses the qualification of Bachelor of Physical Education on completing the three year degree course would be eligible to be appointed as PTI Grade-III and the non-consideration of such a candidate merely by using a short form of 'BPE' and distinguishing it from 'BPEd' is a misnomer and an attempt to deprive the more meritorious candidates from appointment.”

Accordingly, the special appeal was allowed and the candidature of the appellants was directed to be considered on merits.

Title: Bimla Kumari v State of Rajasthan & Ors., and other connected petitions

Citation: 2025 LiveLaw (Raj) 410

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