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4. In exercise of the powers conferred by Section 26(1)(e) of the said Act, the UGC framed regulations in 1982 prescribing the qualification for the teaching post of Lecturer in colleges as follows:-

"M. Phil. degree or a recognised degree beyond Master's level".

In 1986, the Malhotra Committee was appointed by the UGC to examine various features of University and College education. It recommended that there should be certain minimum qualifications laid down for the post of Lecturer. Pursuant to the said Committee report, the UGC framed regulations on 19th September, 1991 superseding the 1982 regulations and providing apart from other qualifications, clearing of the NET as a test for eligibility to become a Lecturer. Vide an amendment dated 21st June, 1995, a proviso was added to the 1991 regulations by which candidates who have submitted their Ph.D. thesis or passed the M. Phil. examination on or before 31st December, 1993 are exempted from the said eligibility test for appointment to the post of Lecturer. This continued till 2002, the only change made being that the exemption continued qua Ph.D. thesis holders for dates that were extended till 31st December, 2002. This state of affairs continued until 2008 when the Mungekar Committee submitted its final report recommending that NET should be made a compulsory requirement for appointment of Lecturer in addition to the candidate possessing M.Phil. or Ph.D degrees. On 12th November, 2008, the Department of Higher Education, Ministry of Human Resources Development, Government of India, issued a directive under Section 22 of the UGC Act providing inter alia as under:-

"UGC shall, for serving the national purpose of maintaining standards of higher education, frame appropriate regulations within a period of thirty days from the date of issue of this order prescribing that qualifying in NET/SLET shall generally be compulsory for all persons appointed to teaching positions of Lecturer/Assistant Professor in Higher Education, and only persons who possess degree of Ph.D. after having been enrolled/ admitted to a programme notified by the Commission, after it has satisfied itself on the basis of expert opinion, as to be or have always been in conformity with the procedure of standardization of Ph.D. prescribed by it, and also that the degree of Ph.D. was awarded by a University or Institution Deemed to be University notified by the UGC as having already complied with the procedure prescribed under the regulations framed by the Commission for the purpose."