Supreme Court Protects Completed Education, Directs Release of Marksheets and Degree Despite Invalidated OBC Claim

A bench of Justices B.R. Gavai and Augustine George Masih heard an appeal against a Division Bench judgment of the Bombay High Court, Aurangabad Bench, which had dismissed a writ petition seeking release of marksheets and a degree certificate after the appellant’s claim to OBC status was invalidated. The appeal arose from a challenge to the High Court’s refusal to grant relief when the university withheld the academic documents following scrutiny of the appellant’s caste certificate.

The Court allowed the appeal in the peculiar facts of the case and directed the respondents to release the appellant’s marksheets and degree certificate within four weeks. The bench emphasised protection of the education already completed while making clear that the appellant would not be entitled to "any of the benefits as are available to the members of OBC Category" going forward. The Court, in its reasoning, observed: "In the peculiar facts and circumstances, as the appellant has already completed his course, we find that the education undertaken by the appellant herein deserves to be protected. We, however, clarify that the appellant would hereinafter not be entitled to any of the benefits as are available to the members of OBC Category. In that view of the matter, the respondents are directed to release the marks sheets and degree certificate of the appellant within a period of four weeks from today." The Court further stated that the order was passed "in the peculiar facts and circumstances of the case" and would not be treated as a precedent.

Background

The appellant, claiming to belong to the Kunbi caste within the OBC category, secured admission in 2015 to a B.Tech (Chemical Engineering) seat reserved for OBC candidates. His caste certificate was sent to the university Scrutiny Committee for verification but remained undecided for an extended period. The appellant approached the Bombay High Court, Nagpur Bench, in 2017; the Division Bench there, by its order dated 10 February 2020 in Writ Petition No. 5170 of 2017, noted delay and the "callous attitude of the Members of the Scrutiny Committee" and directed the claim to be decided within a stipulated time while awarding costs of Rs. 75,000 to the appellant payable by the three committee members.

Subsequently the caste claim was invalidated and the university withheld the appellant’s mark-sheets and degree certificate. The appellant filed a writ petition before the Aurangabad Bench of the Bombay High Court seeking release of those academic documents; the High Court rejected the petition on the ground that the appellant was no longer entitled to OBC status and therefore no relief was warranted. The appellant obtained leave from the Supreme Court and filed the present appeal.

The Supreme Court examined the procedural delay in adjudication by the Scrutiny Committee and the fact that the appellant had completed the academic course. Finding that the completed education deserved protection in the "peculiar facts and circumstances" of the case, the Court directed release of the academic records within four weeks, but clarified that this relief did not extend to any affirmative benefits associated with OBC status. The bench expressly limited the scope of its order and held that it should not be treated as a precedent. The appeal was disposed of accordingly; no respondent counsel appeared before the Court.

Case Details: Case No.: 2025 INSC 722 Case Title: Anand Sheshman Patel v. The Registrar North Maharashtra University and Another Appearances: For the Petitioner(s): Ms. Shilpa Giratkar, Advocate For the Respondent(s): None appeared