Scope of Statutory Regulations vis-a-vis State Recruitment Rules

The statutory power conferred under Section 23(1) read with Section 10 of the All India Council for Technical Education Act, 1987 empowers the AICTE to frame regulations and lay down norms for quality standards, curricula, and staff qualifications in technical institutions. However, the scope of such regulations is determined by their internal architecture, context, and purpose rather than a generic reading of statutory supremacy. Where regulations are specifically designed as promotion and career progression rules, they cannot automatically override or abolish State recruitment rules framed for direct open recruitment. Regulations intended to govern career advancement presuppose an existing institutional profile and service record within the academic framework. Attempting to stretch such promotional rules to displace direct recruitment norms misconstrues the legislative scheme behind the statute. Statutory authority granted to regulate academic standards does not equate to an absolute mandate to dismantle State recruitment frameworks. Courts must carefully examine the exact field of operation of both sets of rules before declaring a statutory conflict. The boundary between central regulatory standards and State recruitment procedures must be respected to maintain systemic coherence. (Gujarat Public Service Commission v. Gnaneshwary Dushyantkumar Shah & Ors. | 2026 INSC 70)