Institutions Cannot Disregard Accreditation Mandates After Giving Undertakings: Rajasthan HC

The Rajasthan High Court has held that private agriculture colleges cannot evade mandatory requirements for ICAR accreditation after having previously submitted undertakings to comply with state policy. The Bench emphasized that the principles of acquiescence and 'approbation and reprobation' bar institutions from challenging regulatory conditions they once accepted to secure temporary operational permits.

A Single Judge Bench of Dr. Justice Nupur Bhati heard the batch of petitions on a Sunday, acknowledging the extreme urgency as the deadline for student admissions for the Academic Session 2026-27 was fast approaching. The petitioners, including Mayurakshi College of Agriculture, had challenged the State's refusal to grant No Objection Certificates (NOCs) based on non-compliance with the Policy of 2022.

Key Takeaways

Mandatory Quality Standards

Accreditation is no longer an optional badge of honor but a substantive regulatory mechanism essential for maintaining academic and institutional standards in higher agricultural education.

Doctrine of Acquiescence Applied

Institutions that accept temporary benefits under a specific policy and furnish undertakings to comply with its conditions cannot later challenge the validity or retrospective application of that policy.

Immediate Policy Enforcement

Courts will uphold policy clauses that stipulate 'immediate effect,' ensuring that existing institutions must align with new quality benchmarks within prescribed timelines to continue admitting new students.

Judicial Refusal of Equitable Indulgence

Institutions failing to demonstrate even a 'bona fide' effort to apply for accreditation will not receive equitable relief from the courts against the consequences of their own omissions.

The Mandatory Nature of ICAR Accreditation

The Rajasthan High Court rejected the petitioners' argument that accreditation from the Indian Council of Agricultural Research (ICAR) was merely optional. It noted the progressive shift in the national framework where accreditation became mandatory for institutions to receive grants and admit students through national entrance exams. The Bench highlighted that accreditation serves a substantive purpose, including the evaluation of faculty strength, instructional facilities, and curricula.

The Rajasthan High Court concluded that "The petitioners cannot be permitted to disregard the conditions attached to the temporary NOCs merely because compliance with those conditions has subsequently become inconvenient or onerous. Such conduct attracts the principle of acquiescence and the doctrine of approbation and reprobation, insofar as the petitioners accepted the benefit of the NOCs without contemporaneously objecting to the conditions governing their grant."

Ratio

An educational institution that continues operations subject to a regulatory framework and furnishes express undertakings to comply with new policy requirements is bound by the doctrine of waiver and acquiescence. The requirement of ICAR accreditation for agricultural colleges, once incorporated into state policy with immediate effect, is a mandatory quality-assurance condition that cannot be bypassed by existing institutions merely by claiming retrospective hardship.

Background

The petitioners were various agriculture colleges in Rajasthan that had been granted NOCs under an older 2011-12 policy. In 2022, the State introduced a new policy making ICAR accreditation mandatory under Clause 8.4. When the respondents refused to issue NOCs for the 2026-27 session due to the lack of this accreditation, the colleges approached the High Court. They argued that the 2022 policy was being applied retrospectively to them and that accreditation was not a mandatory requirement.

However, the State produced affidavits previously submitted by the petitioners where they had declared they would comply with the 2022 policy. The Rajasthan High Court found that because the petitioners had accepted temporary NOCs for the 2023-24 and 2025-26 sessions under these conditions, they could not now turn around and challenge the policy. The Court distinguished the case from State of Rajasthan & Anr. v. Maharaja Surajmal Agriculture College & Anr., noting that the specific clause (8.4) dealing with existing colleges was not the subject of that earlier ruling. Furthermore, the Rajasthan High Court noted that the petitioners had not even filed an application for accreditation, showing a lack of bona fide effort. The petitions were consequently dismissed, upholding the State's decision to stop new admissions in these colleges.

Case Details:
Case No.: S.B. Civil Writ Petition No. 25369/2026 (and connected matters)
Neutral Citation: [2026:RJ-JD:52107]
Case Title: Mayurakshi College Of Agriculture v. State Of Rajasthan & Ors.
Appearances:
For the Petitioner(s): Mr. C.S. Kotwani with Mr. Chinmoy Shekhar Kotwani.
For the Respondent(s): Mr. Nathu Singh Rathore, AAG with Mr. Arpit Samaria, Mr. Deepesh Singh Beniwal.

Source: 2026 CaseBase(RAJ) 26035