22 July 2025 Civil Appeals >> Civil & Consumer Law  

In a case of Sakshi Chauhan v/s Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni & Another involving a student's admission to a postgraduate program, the Supreme Court of India addressed a dispute concerning the eligibility criteria of Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni, Solan, HP (Respondent No. 1). The appellant, who had completed her B.Sc. (Hons.) in Agriculture from a private university (Eternal University, Baru Sahib, Sirmour, HP, Respondent No. 2) recognized by the UGC, applied for an M.Sc. program for the academic session 2020-21.

Due to the COVID-19 pandemic, the entrance test was canceled, and merit was determined based on marks from qualifying degrees. The university subsequently issued a series of notices and addendums, clarifying that candidates from non-State Agricultural Universities (SAUs), non-Central Agricultural Universities (CAUs), and non-Central Universities (CUs), as well as private universities not accredited by the Indian Council of Agricultural Research (ICAR), were ineligible. As a result, the appellant's candidature was rejected.

The appellant challenged this decision in the High Court of Himachal Pradesh. While the case was pending, the appellant was provisionally admitted to the M.Sc. Environmental Management course against a self-finance seat. The High Court ultimately dismissed her petition, but she was permitted to continue her studies during the appeal process and successfully completed the course, receiving her degree on May 4, 2023.

Following the dismissal of her appeal by the Division Bench of the High Court, the university withdrew her degree on August 5, 2023. The appellant then appealed to the Supreme Court. The Supreme Court found that the university's changing eligibility criteria caused confusion. Given that the appellant had completed her two-year course with good marks and that her ineligibility was solely based on the university's evolving criteria and not on a lack of a qualifying degree, the court exercised its power under Article 142 of the Constitution of India to do "complete justice."

The court regularized her admission, upheld the conferral of her postgraduate degree, and set aside the High Court's judgments. The appeal was allowed, and the university was directed to restore her degree.