Court’s Decision:
The Delhi High Court found the University of Delhi (DU) in wilful disobedience of its previous order directing it to allocate seats to minority students in the petitioner college’s Postgraduate (PG) courses. The court noted that DU’s delay in admitting students has jeopardized their academic future and directed the Registrar and the Dean of Admissions to appear through video conferencing to explain why they should not be penalized under the Contempt of Courts Act, 1971.
Facts:
The petitioner, a minority institution, filed a contempt petition alleging non-compliance with the court’s judgment dated 22.04.2024, which directed DU to ensure proportional seat allocation for the petitioner college in PG courses. The dispute arose because the petitioner college’s minority students were not admitted despite being shortlisted and selected through interviews as per the court’s directions. DU had argued that there was no separate quota for Christian minority candidates in PG courses and that the seats allocated to the petitioner college had been significantly reduced over the years.
Issues:
- Whether the University of Delhi failed to comply with the court’s previous order regarding seat allocation for minority students?
- Whether the university’s actions constituted wilful disobedience, warranting initiation of contempt proceedings?
Petitioner’s Arguments:
The petitioner argued that despite repeated communications and submission of the list of selected candidates, DU failed to allocate the appropriate number of seats for PG courses. The petitioner highlighted that the number of seats was reduced from 37 in the academic year 2021-2022 to 18 in 2024-2025, which adversely impacted the academic future of the selected students. The petitioner emphasized that DU’s refusal to consider the petitioner college’s interview process for minority students ran contrary to the directions of the court and existing judicial precedents.
Respondent’s Arguments:
DU contended that there is no separate quota for minority students in PG courses and that the previous order of the court did not mandate any separate reservation for Christian minority candidates. It maintained that the allocation of seats was based solely on merit through the Common University Entrance Test (CUET) scores and categorization under General, OBC, SC, ST, and EWS categories.
Analysis of the Law:
The court examined its previous order, which allowed the petitioner college to allocate 15% marks for interviews and 85% for CUET scores for minority students. The court observed that DU’s actions effectively undermined the decision, impacting the rights of the minority institution to administer its educational affairs. Further, the court reiterated that although there is no explicit quota for Christian minority students in PG courses, DU is obligated to follow its own stated policies and ensure proportional seat allocation.
Precedent Analysis:
The court referred to Ahmedabad v. St. Xaviers College Society (1970) 2 SCC 417 and St. Stephen’s College v. University of Delhi 2022 SCC OnLine Del 2893, reiterating that minority institutions enjoy autonomy under Article 30 of the Constitution but must adhere to reasonable state regulations ensuring fairness and transparency in admissions.
Court’s Reasoning:
The court noted that despite clear directions in its earlier order, DU did not take necessary steps to ensure compliance, thereby causing prejudice to the petitioner college and its students. The court found that DU’s actions were neither justified nor sustainable in law and demonstrated a deliberate intention to avoid compliance.
Conclusion:
The court held DU’s delay and inaction as constituting contempt of court and directed the Registrar and Dean of Admissions to show cause why they should not be held liable for wilful disobedience of court orders. The matter is scheduled for further hearing on 15.10.2024.
Implications:
This judgment reaffirms the autonomy of minority institutions under Article 30 and their right to administer educational affairs. It also underscores the importance of compliance with judicial directions by state institutions, emphasizing that educational institutions must prioritize the academic future of students over administrative disagreements.
