-
by sayum
07 July 2026 3:12 PM
“Eligibility Was Never Clearly Spelt Out, Addendums Created Confusion”: On 22nd July 2025, the Supreme Court of India, exercising civil appellate jurisdiction, invoked its powers under Article 142 of the Constitution to restore a postgraduate degree that had been unjustly withdrawn by a State Agricultural University after the student had completed her full course.
A bench of CJI B.R. Gavai and Justice Augustine George Masih came down heavily on the University's failure to maintain clarity in admission norms and held:
“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.”
Degree Cancelled After Course Completion Due to Retrospective Ineligibility
The Appellant, Sakshi Chauhan, had applied in May 2020 for admission to M.Sc./MBA (Agri Business) at Dr. Yashwant Singh Parmar University, having completed her B.Sc. Agriculture from Eternal University, a UGC-recognized private university. Owing to the COVID-19 pandemic, the university shifted from an entrance test to a merit-based admission system.
Initially considered eligible and provisionally admitted to M.Sc. Environmental Management, Sakshi completed her degree with distinction and was awarded her diploma on 04.05.2023. However, the university withdrew the degree on 05.08.2023, citing ineligibility based on retrospective addendums which excluded students from private, non-ICAR-accredited institutions.
The Court remarked: “There appears to be some confusion even at the end of Respondent No. 1 University… addendums created confusion… the benefit should go to the Appellant, especially when she had completed her course with good marks.” [Paras 22–23]
High Court Dismissed Plea, But SC Steps In Under Article 142
While the Himachal Pradesh High Court (both Single and Division Benches) had upheld the University's cancellation, the Supreme Court overruled both and took a firm stance to protect the rights of the student:
“This would be a fit case where jurisdiction as conferred under Article 142… needs to be exercised for regularizing her admission… and upholding the conferring of the postgraduate degree.” [Para 26]
Unclear Prospectus, Delayed Amendments and Administrative Ambiguity
The bench criticized the University's shifting goalposts, noting that the Prospectus of May 2020 (Clause 3.1) did not clearly disqualify candidates from private universities. The Court found it crucial that:
“If the Prospectus had been clear… the application of the Appellant… should have been, at the very outset, rejected.” [Para 15]
“Universities must exercise diligence in declaring eligibility criteria in time to prevent harm to students.” [Para 22]
Degree Restored, High Court Judgments Set Aside
In a conclusive ruling, the Supreme Court held:
“The Appellant shall be conferred with degree as completed by her in accordance with due process… the withdrawal of the said postgraduate degree… is rendered otiose.” [Para 27]
The judgments of the Himachal Pradesh High Court were set aside, and Sakshi Chauhan's academic credentials restored with immediate effect.
Date of decision: 22/07/2025
