22 July 2025 Civil Appeals >> Civil & Consumer Law  

This case of Sakshi Chauhan v/s Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni & Another concerns an appeal filed by a student challenging the rejection of her admission and subsequent withdrawal of her postgraduate degree by Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni, Solan, HP (Respondent No. 1).

Background of the Case:

The appellant applied for an M.Sc./MBA (Agri Business Programme) for the 2020-21 academic session, having completed her B.Sc. (Hons.) in Agriculture in 2020 from Eternal University, Baru Sahib (Respondent No. 2), a private university recognized by the University Grants Commission (UGC). Due to the COVID-19 pandemic, the entrance test was canceled, and admission was to be based on qualifying degree marks.

The appellant's application was initially processed, but on December 3, 2020, Respondent No. 1 issued a notice stating that candidates from non-State Agricultural Universities/Central Agriculture Universities/Central Universities (SAUs/CAUs/CUs) were ineligible. This was followed by addendums on December 11 and December 15, 2020, further clarifying that graduates from private agricultural universities/colleges not accredited by the Indian Council of Agricultural Research (ICAR) were also ineligible. As Respondent No. 2 was a private university not accredited by ICAR, the appellant's candidature was rejected.

Proceedings in the High Court:

The appellant challenged the changing eligibility criteria and the rejection of her candidature in the Himachal Pradesh High Court. An interim order allowed her to participate in counseling, and she was provisionally admitted to the M.Sc. Environmental Management course on a self-finance seat. The learned Single Judge dismissed her writ petition, upholding her ineligibility, though without adverse comments on her merit. The appellant's intra-court appeal was also dismissed by the Division Bench, leading to the present appeal before the Supreme Court. During the pendency of the appeal, the appellant completed her M.Sc. Environmental Management course and was awarded the degree on May 4, 2023, which was subsequently withdrawn by Respondent No. 1 on August 5, 2023.

Supreme Court's Analysis and Decision:

The Supreme Court acknowledged the confusion and uncertainty caused by Respondent No. 1's changing eligibility criteria. It noted that the initial prospectus, when the appellant applied in May 2020, was not explicitly clear that a candidate from a UGC-recognized private university would be ineligible. The subsequent notices and addendums created ambiguity, and had the rejection been immediate, the appellant could have sought admission elsewhere.

The Court emphasized that the appellant had completed her course with good marks, investing two valuable years of her career. It was undisputed that, apart from the initial question of eligibility based on the type of university, the appellant fulfilled all other academic requirements, including attendance and examination performance.

Considering the potential for irreparable loss to the student, the Supreme Court deemed this a fit case to exercise its powers under Article 142 of the Constitution of India to do complete justice. This extraordinary power allows the Supreme Court to pass any decree or make any order necessary for doing complete justice in any cause or matter pending before it.

The Court concluded that depriving the appellant of her degree at this stage would be inappropriate and unjust. Consequently, it regularized her admission to the M.Sc. Environmental Management course and upheld the postgraduate degree conferred upon her. The subsequent withdrawal of the degree was rendered void.

Outcome:

The appeal was allowed. The judgments of both the Single Bench and the Division Bench of the Himachal Pradesh High Court were set aside. Respondent No. 1 University was directed to confer the degree on the appellant as completed by her in accordance with due process.