Court’s Decision
The Supreme Court, exercising its powers under Article 142 of the Constitution, set aside the judgments of the Himachal Pradesh High Court and regularised the admission and degree of a student whose postgraduate degree had been withdrawn on grounds of initial ineligibility. The Court held that:
“By depriving her of her degree at this stage would not be appropriate and may end up in injustice to a student who had invested two important and valuable years of her career leading to an irreparable loss.”
The apex court held that the candidate, having completed her M.Sc. in Environmental Management with good marks and full compliance with academic requirements, deserved the benefit of the doubt arising from the University’s own confusion over eligibility standards. The University was directed to restore the degree and treat the notification withdrawing the same as ineffective.
Facts
The appellant had applied in May 2020 for admission to the M.Sc./MBA (Agri Business) Programme at Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Solan, Himachal Pradesh. She held a B.Sc. (Hons.) Agriculture degree from Eternal University, a UGC-recognised private university. While the original prospectus accepted degrees from UGC-recognised institutions, subsequent addenda introduced additional restrictions—such as requiring ICAR accreditation and excluding non-State Agricultural Universities—which were not part of the original terms.
Due to the COVID-19 pandemic, entrance tests were cancelled, and merit was determined on the basis of undergraduate performance. Although her application was initially accepted, she was later declared ineligible and denied a seat. The appellant challenged this in the Himachal Pradesh High Court, which allowed her to provisionally pursue the course. She completed the M.Sc. Environmental Management course and was awarded her degree on 4 May 2023. However, the University withdrew her degree via a notification dated 5 August 2023, prompting the present appeal.
Issues
- Whether the appellant was ineligible for admission based on the evolving eligibility criteria introduced post the initial prospectus?
- Whether the University’s withdrawal of her postgraduate degree after course completion was legally sustainable?
- Whether the Supreme Court should exercise its extraordinary jurisdiction under Article 142 to render complete justice?
Petitioner’s Arguments
The appellant contended that the eligibility criteria were not clearly communicated in the original prospectus and that the subsequent addenda caused confusion and delay in the admission process. She argued that she was eligible under the original clause which only required a B.Sc. degree from a UGC-recognised institution. If her application had been rejected at the outset, she could have sought admission elsewhere.
She emphasised that after receiving provisional admission, she diligently completed the course, fulfilled attendance requirements, passed examinations with good marks, and was awarded a degree. The withdrawal of the degree after two years of hard work was unjust and should be set aside using Article 142.
Respondent’s Arguments
The University argued that the appellant was ineligible from the start as she did not hold a degree from a SAU/CAU/CU or ICAR-accredited institution. It was contended that the addenda merely clarified existing eligibility norms rather than changing them. The grant of provisional admission did not confer any vested right. Hence, the University acted within its rights in withdrawing the degree.
However, it was not disputed that the appellant had completed the course with commendable academic performance and fulfilled all institutional requirements except for the initial eligibility clause.
Analysis of the Law
Clause 3.1 of the original prospectus prescribed that applicants must hold a relevant undergraduate degree from a UGC-recognised institution. There was no initial bar against private universities or requirement of ICAR accreditation. The addenda issued in December 2020 introduced stricter norms—excluding private institutions and requiring ICAR accreditation.
The Court noted the lack of clarity in the evolving admission criteria and emphasised that such post-hoc exclusions should not defeat a candidate who had already completed the course. The jurisprudence governing admission processes emphasises predictability, transparency, and fairness. Any retrospective change that defeats legitimate expectations must be scrutinised carefully.
Precedent Analysis
Although no specific prior judgments were cited in this ruling, the reasoning reflects established principles from past decisions where the Supreme Court has used its Article 142 powers to regularise admissions or degrees in cases where students, through no fault of their own, suffered due to institutional errors or shifting policies. The court reiterated that procedural irregularities must not result in disproportionate hardship.
Court’s Reasoning
The Supreme Court acknowledged the confusion at the University’s end, as evident from the multiple addenda. The Court held that:
“There appears to be some confusion even at the end of the University requiring clarity at different stages… Under these circumstances, the benefit should go to the Appellant, especially when she had completed her course with good marks by investing two years of hard work.”
It recognised that the appellant’s degree was from a UGC-recognised university and not inherently deficient. Her academic record was untainted, and there was no misconduct or misrepresentation. The Court invoked Article 142, stating:
“This would be a fit case where jurisdiction as conferred under Article 142 of the Constitution of India needs to be exercised for regularizing her admission… and thereafter upholding the conferring of the postgraduate degree.”
Conclusion
The Supreme Court set aside the judgments of both the learned Single Judge and the Division Bench of the Himachal Pradesh High Court. It declared that the degree awarded to the appellant on 4 May 2023 must be treated as valid and the University’s withdrawal notification dated 5 August 2023 would be rendered otiose. The appeal was allowed, and no costs were imposed.
Implications
This judgment is a clear warning to educational institutions against arbitrary or retrospective changes in eligibility norms. It affirms that courts will protect students who, in good faith, rely on existing prospectus clauses and invest years in their education. It also reinforces the utility of Article 142 in correcting systemic unfairness even where technical non-eligibility exists. Importantly, it recognises that justice to students must factor in their bona fides, diligence, and completed academic work.
Referred Cases and Their Relevance
No prior cases were expressly cited in this judgment. However, the Court relied on established precedent concerning the use of Article 142 to ensure fairness and avoid irreparable harm to students due to administrative lapses or ambiguous eligibility norms.
FAQs
1. Can a university withdraw a degree after a student has completed the course?
Only under exceptional circumstances such as fraud or misrepresentation. Courts may intervene, as in this case, where the withdrawal causes disproportionate harm due to institutional confusion or retrospective policy changes.
2. What is the significance of Article 142 in student admission cases?
Article 142 allows the Supreme Court to do complete justice even where procedural irregularities exist. It is often used to regularise admissions or degrees if the student is not at fault.
3. Are degrees from UGC-recognised private universities valid for government university admissions?
Unless specifically excluded in a prospectus or regulation, degrees from UGC-recognised institutions are generally valid. Retrospective disqualifications or vague criteria can be challenged.