Legal Analysis: State of U.P. v. Anjuman Ishaat-e-Taleem Trust & Ors

Citation: 2026 INSC 597

Court: Supreme Court of India

Bench: A Division Bench comprising Justice Dipankar Datta & Justice Manmohan

Date of Decision: May 29, 2026

Nature of Judgment: Review Petition (Civil) Diary No.53434/2025 and connected matters in Civil Appeal No. 1385/2025 – review of the earlier judgment in Anjuman Ishaat-e-Taleem Trust v. State of Maharashtra.

Synopsis of the Judgment

The review petitioners – various States, teachers' associations, and individual teachers – sought review of the judgment in Anjuman Ishaat-e-Taleem Trust v. State of Maharashtra which held that in-service teachers having more than five years of service remaining were required to qualify the Teacher Eligibility Test (TET) within two years from 1st September 2025, failing which they would not be entitled to continue in service. The petitioners argued that the RTE Act could not be applied retrospectively, that Section 12A of the NCTE Act protected pre‑2011 recruits, and that the time granted was insufficient. The Supreme Court, after hearing the review petitions in open court, found no error apparent on the face of the record. However, recognising the practical difficulties and the paramountcy of continuity in elementary education, the Court exercised its power under Article 142 to extend the timeline from two to three years (from 31st August 2027 to 31st August 2028) and directed States to conduct TET periodically. The review petitions were otherwise dismissed.

1. Basic Information of the Judgment

Case Title: State of U.P. v. Anjuman Ishaat-e-Taleem Trust & Ors. (with 65+ connected review petitions)

Citation: 2026 INSC 597

Review Petition No.: Diary No.53434/2025 and connected matters in Civil Appeal No. 1385/2025

Bench: Justice Dipankar Datta (author) and one other Judge

Date of Decision: May 29, 2026

Court: Supreme Court of India (Inherent Jurisdiction)

Impugned Order: Judgment and order dated [not specified] in Anjuman Ishaat-e-Taleem Trust v. State of Maharashtra (Civil Appeal No. 1385/2025).

2. Legal Framework

Major Laws and Provisions Involved

• Right of Children to Free and Compulsory Education Act, 2009 (RTE Act) – Section 23 (qualifications for appointment and terms and conditions of service of teachers), particularly sub-section (1), sub-section (2), first proviso (five years for teachers at commencement), second proviso (four years for teachers in position as on 31st March 2015).

• National Council for Teacher Education Act, 1993 (NCTE Act) – Section 12A (power to determine minimum standards), first proviso (protection for pre‑2011 recruits), second proviso (qualifications to be acquired within period specified in RTE Act).

• Constitution of India, 1950 – Article 21-A (right to education), Article 142 (powers of Supreme Court to do complete justice).

• Code of Civil Procedure, 1908 – Section 114 (review), Order XLVII Rule 1 (

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