Delhi High Court Denies Mid-Session Admissions to DU LLB Program Despite Alleged Vacant Seats, Upholds Finality of Admission Process – Holds “No Endless Admissions Process”

Court’s Decision

The Delhi High Court dismissed the appeal filed by two students seeking admission to the LLB program at the University of Delhi (DU) despite vacant seats. The court ruled that once the admission process is concluded, no further admissions can be granted, even if some seats remain unfilled due to students dropping out. The court emphasized that “admission cannot be an unending process, and mid-session admissions would disrupt academic integrity.”

The appeal was dismissed without costs, upholding the Single Judge’s earlier decision rejecting the petitioners’ request for admission.

Facts

1. Entrance Exam and Admission Process
   • The appellants appeared for the Common University Entrance Test (CUET PG 2024) for admission into DU’s LLB program and scored 176 marks.
   • DU conducted four rounds of Spot Admissions between July 22, 2024, and August 25, 2024, to fill vacant seats.
   • The university declared that all seats were filled after Spot Round IV, which concluded on August 31, 2024.
2. Appellants’ Grievance
   • The appellants claimed that vacant seats still existed after the final round.
   • They were denied admission despite scoring 176 marks, the same as the last admitted candidate.
   • They approached DU’s grievance cell but received no response.
   • An RTI application (filed on September 25, 2024) seeking vacancy details also remained unanswered.
3. Writ Petition and Single Judge’s Decision
   • The appellants filed a writ petition before the Delhi High Court, seeking a direction to grant them admission for the academic year 2024-25.
   • The Single Judge rejected the petition (October 15, 2024), ruling that:
     • Their qualifying exam scores were lower than the last admitted candidate.
     • DU had not admitted any candidate with lower merit than them.
     • Mid-session admissions were not permitted unless exceptional circumstances existed.
   • The appellants challenged this decision before the Division Bench.

Issues Before the Court

1. Did DU wrongfully deny admission to the appellants despite vacant seats?
2. Should mid-session admissions be allowed if seats remain unfilled?
3. Did DU violate University Grants Commission (UGC) guidelines by not filling all vacant seats?
4. Did DU provide contradictory justifications regarding vacant seats and admission criteria?

Petitioners’ (Appellants’) Arguments

1. DU Failed to Fill Vacant Seats
   • The appellants contended that vacant seats still existed after Spot Round IV and DU wrongfully denied them admission.
   • They claimed that DU’s admission data was inconsistent, as some seats remained unfilled while students with the same CUET score were admitted.
2. Discrepancy in DU’s Statements
   • The appellants alleged that DU gave contradictory explanations in its affidavits before the Single Judge and the Division Bench.
   • Initially, DU claimed that the qualifying exam score was the deciding factor.
   • Later, DU stated that all vacant seats were filled, contradicting its earlier stance.
3. UGC Guidelines Mandate Filling of Vacant Seats
   • The appellants relied on a UGC letter dated June 7, 2024, which directed universities to ensure that no seats remain vacant.
   • They argued that DU had violated this directive by closing admissions prematurely.
4. Judicial Precedents Supporting Their Case
   • The appellants cited the case of Deepanshu Khanna v. University of Delhi (2022 SCC OnLine Del 347), where the court ordered DU to fill vacant seats as per merit.
   • They also referred to Anuj Sharma v. University of Delhi (2011 SCC OnLine Del 4266), which held that prestigious institutions must make every effort to ensure no seat goes to waste.

Respondent’s (DU’s) Arguments

1. Tie-Breaker Rule Was Correctly Applied
   • DU argued that while the appellants scored 176 marks in CUET, their qualifying exam scores were lower than those of the last admitted candidate.
   • The Tie-Breaker Rule (as per Chapter 13 of DU’s Admission Guidelines) prioritizes CUET scores, but in case of a tie, the qualifying exam marks are considered.
   • The last admitted candidate had:
     • 73.50% (Law Centre-I) and 81.30% (Law Centre-II)
     • Appellant No. 1: 66.20%
     • Appellant No. 2: 68.71%
   • Since their scores were lower, they were not eligible for admission.
2. All Seats Were Filled by August 31, 2024
   • DU maintained that all seats were filled after Spot Round IV, and no further admissions were possible.
   • Any seats that became vacant after the final round were due to students leaving mid-session, which does not require fresh admissions.
3. Finality of Admission Process
   • DU cited Neelu Arora v. Union of India (2003 SCC OnLine SC 119), where the Supreme Court ruled:
     • “Mid-session admissions disrupt academic integrity.”
     • Once the admission deadline passes, seats cannot be filled indefinitely.
4. No Contradiction in DU’s Affidavits
   • DU explained that the alleged contradiction was a misunderstanding.
   • Initially, six-semester scores were considered, but as per DU’s admission policy, only five-semester scores were used in the final tie-breaker calculations.

Analysis of the Law

1. Finality in Admissions
   • The Supreme Court has consistently held that once admissions close, no further admissions can be made, even if seats remain unfilled.
   • Medical Council of India v. Madhu Singh (2002 SCC 258) ruled that admitting students midstream would disrupt academic discipline.
2. Vacancies vs. Mid-Session Vacancies
   • The court distinguished genuine vacant seats from seats that become available mid-session due to student withdrawals.
   • Universities are not obligated to keep admitting students indefinitely for dropped-out seats.
3. No Evidence That DU Violated UGC Guidelines
   • The court found no proof that DU failed to comply with UGC’s SOPs on vacant seats.
   • Since DU categorically stated that all seats were filled, the petitioners’ reliance on UGC guidelines was misplaced.

Court’s Reasoning

1. DU’s Admission Process Followed Merit-Based Selection
   • The Tie-Breaker Rule was correctly applied; the appellants had lower scores than the last admitted student.
2. No Evidence of Unfilled Seats
   • The court accepted DU’s assertion that all vacant seats were filled by August 31, 2024.
3. Finality of Admissions Upheld
   • The Supreme Court’s ruling in Neelu Arora was followed: once the admission cut-off is reached, the process must conclude.
4. No Contradictions in DU’s Affidavits
   • The alleged discrepancies were satisfactorily explained, and no deliberate misinformation was found.

Conclusion

The Delhi High Court dismissed the appeal, ruling that:

• Mid-session admissions are impermissible, even if seats become vacant later.
• DU properly followed the tie-breaker rule, and no less-meritorious student was admitted.
• DU complied with UGC norms, and no evidence of unfilled seats existed.
• The university’s statements were consistent and did not warrant judicial interference.

Implications

• Strengthens finality in university admissions.
• Reinforces tie-breaker criteria in merit-based admissions.
• Prevents indefinite legal challenges to admissions.
• Clarifies that mid-session vacancies do not mandate fresh admissions.

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