University’s Error Can’t Cost a Student Her Future: Supreme Court Directs Manav Bharti University to Issue Withheld Degree and Marksheets Due to Clerical Mistake

“Exclusion of the Appellant’s name in the admission disclosure list occurred due to no fault on her part... she cannot be made to suffer for a purely clerical mismatch.”- In a significant judgment protecting student rights and ensuring institutional accountability, the Supreme Court on January 6, 2026, in Pratima Das vs. State of Himachal Pradesh & Ors., set aside a Himachal Pradesh High Court order that had relegated a bona fide law graduate to seek remedies through civil courts after her academic documents were unjustly withheld for over two years.

A Bench comprising Justice Vikram Nath and Justice Augustine George Masih held that the Appellant had completed all academic requirements for her BA.LLB. degree from Manav Bharti University (MB University), and the non-issuance of her marksheets and degree for semesters 5 to 10 was the result of an “inadvertent and unintentional clerical error” by the University.

“It is undisputed that the Appellant has been a bona fide student of MB University and had cleared all her examinations... the same is at the hands of the University for which the Appellant cannot be made to suffer,” the Court held, allowing the appeal and directing MB University to issue all pending academic documents within four weeks.

Supreme Court Slams Delay and Denial: “No Factual Dispute Left To Decide”

The Court strongly disagreed with the Himachal Pradesh High Court’s December 20, 2024, order which had disposed of a Public Interest Litigation (PIL) concerning MB University students and left the petitioners to seek individual remedies in other forums.

“Having regard to the above established facts based on records, we are of the view that the Appellant has been deprived of her documents for no fault of hers for a substantial period of time and relegating her to another court of competent jurisdiction... would no more be required as there is no factual dispute left,” the Bench observed.

This holding came after MB University itself, now under the control of the Himachal Pradesh Government, filed an affidavit on December 3, 2025, admitting the error and confirming that Pratima Das was a bona fide student enrolled under Admission No. R17BALLB0033 and Registration No. MBU-2017-0536 for the 2017–2022 academic session.

Clerical Error and Criminal Investigations: The Complex Backdrop

The appellant, Pratima Das, had joined the BA.LLB. five-year course in 2017 and completed all ten semesters by 2022. However, her 5th to 10th semester marksheets and final degree were not issued. The reason cited was a mismatch in the admission disclosure list submitted by the previous administration of the University to regulatory authorities.

Her name, despite being correctly entered in the University's Green Register and other internal records, was missing in the admission disclosure list, where instead, the name of one Mr. Ayaan Narwal was incorrectly entered against her admission number. Mr. Narwal was a student from a different batch (2016–2021), and the University admitted this as a clerical mismatch.

The issue was compounded by a pending criminal investigation against the University related to the alleged sale of fake degrees, which had led to the seizure of records in 2019 and created widespread difficulties for genuine students in obtaining their documents.

The Supreme Court acknowledged the hardship:

“Non-supply of documents has put her career at stake and such grave prejudice has been caused for no fault of hers.”

Internal Records and University Affidavit Left No Room for Doubt

In its additional affidavit dated December 3, 2025, MB University clearly acknowledged:

• The Appellant was validly admitted under the BA.LLB. programme.
• She completed all semesters and had already been issued the 1st to 4th semester mark sheets.
• Her name appeared in the University’s Green Register and internal academic records.
• The mismatch in the disclosure list was an inadvertent human error by the earlier administration, not involving any suppression, manipulation, or mala fide intent.

“The University has consistently maintained the Petitioner’s academic records, internal registers, examination entries, and result data, thereby proving that she was a bona fide student throughout,” the affidavit stated.

In light of these admissions, the Supreme Court found no dispute requiring further adjudication.

Rejection of Mechanical Reliance on Disclosure List

Importantly, the Court rejected the mechanical reliance placed by authorities on the flawed admission disclosure list. It emphasized that once other contemporaneous records — including the Green Register, exam entries, attendance, and internal assessments — corroborate the student’s bona fide status, the omission in one list cannot be the sole basis to deny her degree.

“It was the duty of MB University and other concerned authorities to include her name in the Admission Disclosure list on which she had no control,” observed the Court.

The earlier refusal by the record custodian to issue the documents, merely due to the disclosure list mismatch, was found unjustified and prejudicial.

Supreme Court Relief: University Directed to Issue All Documents Within 4 Weeks

The Supreme Court ultimately allowed the appeal and directed MB University to issue the appellant’s marksheets for 5th to 10th semesters, her degree certificate, and any other relevant academic records within four weeks from the date of the judgment.

“The Appellant cannot be punished for University's error,” the Court held, highlighting that justice demanded immediate relief, not further litigation.

This decision marks a critical affirmation of student rights, especially in cases where administrative failures or institutional errors unfairly affect academic progression and future career opportunities.

It also sets a precedent that clerical errors by educational institutions, especially during ongoing criminal or regulatory proceedings, cannot be allowed to result in blanket denial of legitimate student entitlements, particularly where the facts are undisputed.

Date of Decision: January 6, 2026