Administrative Lapse Of University Cannot Penalize Student By Denying Verification Of Academic Credentials: Supreme Court

"The omission of his name from the admission disclosure list is, on the University’s own admission, a lapse on its part in which the Appellant had no role. Such a lapse cannot be visited with adverse consequences upon the Appellant, nor can it be a ground for withholding the verification of his academic credentials." Supreme Court, in a ruling dated 14 October 2026, held that students cannot be made to suffer or have their academic credentials denied verification due to administrative lapses or clerical errors committed by a university.

A bench comprising Justice Vikram Nath, Justice Augustine George Masih, and Justice Sandeep Mehta observed that when a student is a bona fide enrollee who has cleared all prescribed examinations, the university’s failure to include their name in regulatory disclosure lists is an internal error for which the student cannot be penalized.

The appellant, a student of Manav Bharti University, successfully completed his B.Tech (Civil Engineering) course in 2018. Following his appointment as a Sub-Inspector, his employer sought verification of his degree; however, the verification remained pending for years because the university’s records had been seized by a Special Investigation Team amid allegations of the illegal sale of degrees. Although the appellant’s name appeared in the university’s primary 'Green Sheet' and examination records, his name was missing from the admission disclosure list submitted to the Himachal Pradesh Private Educational Institutions Regulatory Commission, leading to the withholding of his salary and service confirmation.

Scope of Judicial Review

The primary legal issue before the Court was whether the state, through its verification committee, could deny the certification of a student’s credentials based on the university's failure to maintain proper administrative disclosures. The Court further examined whether, in the face of established academic success, a student should be relegated to a civil court to resolve discrepancies arising solely from the university’s internal clerical failures.

University’s Administrative Lapse

The Court noted that the university, in its counter affidavit, explicitly admitted that the appellant was a bona fide student admitted against allotted seats and that his failure to appear in the disclosure list was due to "clerical and inadvertent human error" by the previous administration. The bench emphasized that the appellant had no control over these administrative processes and that penalizing him for such lapses would be both burdensome and inequitable.

"No Adverse Consequences for Students"

The judges remarked that the internal records, such as the Green Sheet, served as primary evidence of his enrollment and academic performance. The Court observed that once a student’s status as a bona fide enrollee who has cleared all examinations is established, the university is duty-bound to rectify its records rather than frustrate the student's career prospects.

Addressing the Mismatch of Marks

Regarding a minor discrepancy in the reported marks of the 7th and 8th semesters, the Court observed that these variations did not alter the fundamental fact that the appellant had passed the examinations. The bench held that the limited exercise of verifying the correct set of marks from official records was an administrative responsibility that did not require the appellant to lead fresh evidence or approach a lower court.

"The discrepancy, thus, does not touch upon the admission of the Appellant, his status as a student at University, or the fact that he passed the course."

Setting aside the High Court’s order that had relegated the appellant to a competent civil court, the Supreme Court directed the State to provide all necessary result records to the university. The university was ordered to issue corrected Detailed Marks Certificates to the appellant within three weeks and forward the verification report to his employer. Upon such verification, the employer was directed to release all arrears of salary and consequential benefits to the appellant within four weeks.

Date of Decision: 14 October 2026

Case Title: Mohd. Asad Choudhary vs. State of Himachal Pradesh and Others | Civil Appeal No. of 2026 (Arising out of SLP (C) No.474 of 2026)

Bench: Justice Vikram Nath, Justice Augustine George Masih, and Justice Sandeep Mehta