Supreme Court regularises admission and upholds postgraduate degree where university changed eligibility criteria mid-process

A bench of Chief Justice B. R. Gavai and Justice Augustine George Masih heard an appeal by a student challenging her ineligibility for admission to a postgraduate programme after the university amended eligibility criteria and later withdrew the degree conferred on her. The appeal arose from the Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni, Solan's (Respondent No.1) exclusion of candidates who obtained B.Sc. (Agriculture) from certain private agricultural universities not accredited by ICAR, and the subsequent withdrawal of a degree awarded to the appellant after she completed an M.Sc. programme provisionally.

The Court allowed the appeal, set aside the impugned High Court judgments and regularised the appellant’s admission and degree. The Bench noted that the university itself exhibited “confusion” by issuing successive notices and addenda which altered the eligibility landscape during the admission process, and held that equity favoured the student who had completed the course. The Court, in its reasoning, observed: "In our view, this would be a fit case where jurisdiction as conferred under Article 142 of the Constitution of India needs to be exercised for regularizing her admission to the M.Sc. Environmental Management course and thereafter upholding the conferring of the postgraduate degree on 04.05.2023. The consequence thereof would be that the withdrawal of the said postgraduate degree, vide notification dated 05.08.2023, would be rendered otiose." The Court further recorded that “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.”

Background The appellant applied in May 2020, pursuant to a Prospectus (May 2020), for admission to the M.Sc/MBA (Agri Business Programme). The Prospectus initially provided for admissions based on OGPA/qualifying degree marks after the entrance test was cancelled due to COVID-19; the minimum eligibility requirement referred to a B.Sc. from a UGC-recognised university. The appellant held a B.Sc. (Agriculture) (Hons.) from Eternal University (a private university recognised by UGC). In December 2020 the respondent university issued a notice and two addenda (03.12.2020, 11.12.2020 and 15.12.2020) clarifying and tightening eligibility to exclude candidates who graduated from agricultural private universities/colleges not accredited by ICAR, thereby rendering the appellant ineligible. Two lists were prepared and the appellant’s candidature was rejected for M.Sc. Agriculture; she was, however, permitted by the High Court on interim orders to take provisional admission in M.Sc. Environmental Management and to attend classes.

The Single Judge of the Himachal Pradesh High Court dismissed the appellant’s writ petition, holding her ineligible; a Division Bench later dismissed her intra-court appeal. Meanwhile the appellant completed the M.Sc. Environmental Management course and was awarded the degree on 04.05.2023. The University issued a notification on 05.08.2023 withdrawing the degree. The appellant challenged the withdrawal before this Court, arguing that changes to eligibility mid-process caused confusion and that she had been accepted, had fulfilled attendance and assessment requirements, and had completed the course with good marks. The University contended that a candidate ineligible at the outset, admitted provisionally and without any vested right, could not claim regularisation on completion.

The Supreme Court found that eligibility was not “clearly” determinable at the relevant time, that the university’s successive amendments created uncertainty, and that equity required preservation of the degree. Exercising powers under Article 142, the Court regularised the admission, upheld the degree conferred on 04.05.2023 and rendered the withdrawal notification of 05.08.2023 otiose. The impugned High Court orders were set aside. The appeal was allowed and there was no order as to costs.

Case Details: Case No.: 2025 INSC 882 (Civil Appeal @ SLP (C) No. 22269 of 2023) Case Title: Sakshi Chauhan v. Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni & Anr. Appearances: For the Petitioner(s): Counsel not specified in the judgment For the Respondent(s): Counsel not specified in the judgment