Courts Cannot Reopen Admissions Once Deadline Expires: Orissa High Court Rejects SEBC Nursing Aspirants' Plea Filed Post Cut-Off

“Statutory Cut-Off Dates Are Not Elastic Deadlines Open to Judicial Extension” – In a decisive judgment Orissa High Court dismissed a batch of writ petitions filed by students who sought admission into the B.Sc. Nursing course under the SEBC/OBC quota, long after the final cut-off date of 30 November 2024. A Division Bench comprising Justice Manash Ranjan Pathak and Justice Mruganka Sekhar Sahoo observed that “judicial review under Article 226 cannot be exercised to override timelines already prescribed under statutory and regulatory framework.”

The students had sought the benefit of a previous High Court judgment that granted relaxation of minimum qualifying marks to SEBC/OBC candidates, but had not applied within either the original or extended deadlines. The Court unequivocally held that “no relief can be granted as admission beyond the notified date is impermissible.”

“Judgment Granting Relaxation Did Not Extend Final Deadline of 30.11.2024” – No Scope for Fresh Claims After Process Concludes

The core legal issue stemmed from a judgment delivered by a coordinate bench on 26 November 2024 in W.P.(C) No. 25371 of 2024, which directed the counselling authority to allow SEBC/OBC candidates the benefit of 40th percentile marks (in line with Indian Nursing Council norms) for admission to the B.Sc. Nursing course. Following that ruling, the Directorate of Medical Education and Training (DMET), Odisha issued a notification on 27 November 2024, granting only two days’ time—until 29 November 2024, 11:59 PM—for eligible candidates to apply with appropriate documents.

The petitioners in the present batch, however, neither applied during the original process nor responded to the final notification. The High Court noted: “As on date, the judgment dated 26.11.2024 has attained finality not having been challenged by any of the parties. We being the coordinate bench, we agree with the conclusions in the said judgment.”

The Bench further clarified that the earlier judgment did not authorize any further extension. “By the judgment dated 26.11.2024, the coordinate bench had not granted any further extension of time. As a necessary corollary, the authority could not have extended the time,” the Court said, adding that 283 candidates had availed the benefit of relaxation within the stipulated time, and the petitioners’ failure to act could not now be rectified.

“Regulatory Notifications Cannot Be Stretched to Justify Post-Deadline Admissions” – Court Rejects SEBC Petitioners' Reliance on INC Circular

Attempting to salvage their case, some petitioners relied on a notification dated 28 October 2024 issued by the Indian Nursing Council (INC), which spoke of accommodating students in an “irregular batch” up to 30 November 2024. This, they claimed, could justify their admission despite missing the deadline.

The Court rejected the argument outright, holding that “the notification has to be read in the context that students who had applied through the counselling process after the last date of admission was extended till 30th November 2024, can take the benefit. The said notification… cannot be interpreted to hold that students who did not apply and had not taken admission up to extended last date 30th November 2024 can get the benefit.”

The Bench found that the petitioners had “never applied to the Selection Committee for taking admission to the course in B.Sc. Nursing as SEBC/OBC candidates,” and that “none of the petitioners had approached this Court seeking extension of time to fill up admission forms nor was there any interim order in any of the petitions to that effect.”

“Right to Admission Does Not Arise from Inaction” – Court Finds No Procedural Lapse or Violation of Natural Justice

The petitioners also argued that they were unaware of the advertisement dated 27 November 2024, and sought to blame the limited time window for their failure. The Court was not persuaded. “The advertisement was duly published online and 283 candidates availed the benefit within deadline. Petitioners failed to justify their inaction,” it noted.

On the issue of procedural fairness, the Court pointedly remarked: “It is not asserted by the petitioners that they had sought admission to B.Sc. Nursing seeking benefit meant for OBC/SEBC candidates. They also did not seek impleadment in the prior successful writ petitions.”

Further, the Court noted discrepancies in the conduct of some private institutions such as Maa Tarini College of Nursing, which claimed to have admitted some petitioners but failed to submit required student data within the stipulated timeline. The Court refused to entertain these as valid admissions: “In absence of production of data of admission of students by the last date notified, there cannot be any further consideration.”

“Court Cannot Offer Hypothetical Relief for 2025–26 Admissions When Petitioners Never Applied” – No Remedy for Future Session Either

The Bench also addressed a speculative argument raised during the hearing—whether the petitioners could be considered for the academic session 2025–26. The Court clarified that it had no occasion to consider such a question, because the petitioners had not applied for the 2025–26 counselling either.

“We have also asked the learned counsel… whether they can take admission as students for the educational year 2025–2026. In response the answer… is that they have not applied for the selection/counselling conducted for the academic year 2025–26,” the judgment recorded. “Therefore, there is no scope for this Court to consider, ex hypothesi, whether the students can take admission as candidates for academic 2025–26.”

Deadlines Are Not Negotiable

Dismissing the petitions, the Court concluded in clear terms: “We hold that the writ applications are devoid of any merit. Accordingly, the writ applications are dismissed.”

The judgment stands as a strong reaffirmation of the legal principle that courts cannot modify or extend regulatory deadlines, especially in professional courses governed by statutory and central council guidelines. It also sends a clear message that benefit of judicial orders cannot be sought by those who remained completely absent from the process and later sought to rely on extended interpretations or sympathetic considerations

Date of Judgment: 24 December 2025