Delhi High Court Upholds University’s “No Rank Violation” Policy for Offline Counseling: “Admission Process to Ensure Merit-Based Allocation Even in Special Rounds”

Court’s Decision

The Delhi High Court dismissed the petition challenging the policy of Guru Gobind Singh Indraprastha University (GGSIPU), which enforces a ‘No Rank Violation’ rule during its special offline counseling rounds. The Court upheld the University’s stance that maintaining merit standards is crucial, and found no arbitrariness or illegality in the University’s policy decisions regarding admission procedures.

Facts

The petitioners, aspirants for various programs at GGSIPU, contested the notification issued by the University on 29.08.2024, which capped merit ranks for the special round offline counseling. The petitioners argued that this policy deprived them of an opportunity to gain admission to top-ranking affiliated colleges, despite their meritorious standing in various entrance exams. The University’s notification directed affiliated institutes to consider the merit of the last admitted aspirants through online counseling, thereby setting a cutoff that barred eligible candidates like the petitioners from securing a spot during offline counseling.

Issues

1. Whether the University’s policy of ‘No Rank Violation’ in special offline rounds of counseling is arbitrary and violative of Article 14 of the Constitution of India.
2. Whether the University’s policy of merit rank capping unfairly discriminates against meritorious candidates during offline counseling rounds.

Petitioner’s Arguments

The petitioners argued that the merit capping was arbitrary and resulted in a denial of admission opportunities to deserving candidates. They contended that such a policy contradicts the objective of providing merit-based admissions, as it left several seats vacant and hindered the chances of eligible candidates gaining admission in preferred courses and colleges. The petitioners also cited the Supreme Court’s decision in Modern Dental College and Research Centers v. State of Madhya Pradesh (2016) 7 SCC 353, arguing that the University’s action violated fundamental rights under Article 14 of the Constitution.

Respondent’s Arguments

The University argued that its actions were consistent with the GGSIP University Act, 1998, and the Delhi Professional Colleges or Institutions (Prohibition of Capitation Fee, Regulation of Admission, Fixation of Non-exploitative Fee and Other Measures to Ensure Equity and Excellence) Act, 2007. It was stated that the ‘No Rank Violation’ policy has been upheld previously by the High Court and ensures that no less meritorious candidate secures a spot over a more qualified aspirant. The University emphasized that its procedure aimed to maintain academic standards and fairness in admissions, and was not in contravention of any legal provisions.

Analysis of the Law

The Court referred to the T.M.A. Pai Foundation vs. State of Karnataka and P.A. Inamdar vs. State of Maharashtra cases, which emphasize the importance of merit in the admission process. The Delhi Professional Colleges Act, 2007, also mandates merit-based admission through transparent processes. The Court found that the University’s policy was aligned with these legal principles.

Precedent Analysis

The Court cited the decision in Shreyansh Sharma v. Guru Gobind Singh Indraprastha University Through Registrar, 2023:DHC:3126, where a similar policy of ‘No Rank Violation’ was challenged and upheld. The Coordinate Bench had previously noted that this stipulation is essential to ensure that less meritorious candidates do not secure admission in the guise of special rounds of counseling.

Court’s Reasoning

The Court reasoned that the University’s policy ensures fairness by maintaining a consistent merit standard, even in the special offline rounds. The ‘No Rank Violation’ principle, which means that no candidate can be admitted if their rank is lower than that of the last admitted candidate in earlier rounds, was held to be a valid method of preserving academic integrity. The Court found no arbitrariness or violation of constitutional principles in this policy.

Conclusion

The petition was dismissed, and the Court affirmed the University’s policy of maintaining merit-based admissions, even during special offline rounds of counseling. The Court stated that academic policy decisions, especially those related to admissions, should be left to the expertise of the institutions unless there is a clear case of arbitrariness or illegality.

Implications

This ruling reinforces the University’s authority to determine admission standards, including policies for special offline rounds, without compromising on merit. It establishes a precedent that protects the integrity of academic admissions, ensuring that any deviation from merit-based criteria is subject to strict judicial scrutiny.

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