The Supreme Court ruled that the appellant’s admission and subsequent degree in M.Sc. Environmental Management should not be invalidated despite initial eligibility ambiguities. Exercising powers under Article 142 of the Constitution, the Court held that the university’s delayed and unclear addendums caused confusion, and denying the degree after completion would cause irreparable injustice. The withdrawal of the degree was set aside.
Facts Of The Case:
The case involved Sakshi Chauhan, who applied for admission to the M.Sc./MBA (Agri Business) program at Dr. Yashwant Singh Parmar University of Horticulture & Forestry in 2020 based on its prospectus. She held a B.Sc. (Agriculture) degree from Eternal University, a UGC-recognized private institution. Due to the COVID-19 pandemic, the university canceled its entrance exam and instead prepared a merit list based on academic scores. However, in December 2020, the university issued notices and addendums excluding graduates from private universities not accredited by the ICAR, rendering Sakshi ineligible. Despite this, she secured provisional admission to M.Sc. Environmental Management through an interim court order and completed the course with good grades.After obtaining her degree in May 2023, the university withdrew it in August 2023, citing her initial ineligibility. Sakshi challenged this in the Himachal Pradesh High Court, which upheld the university’s decision. On appeal, the Supreme Court noted the university’s inconsistent eligibility criteria and procedural delays, which deprived Sakshi of alternative opportunities. Recognizing her academic efforts and the injustice of revoking her degree post-completion, the Court invoked Article 142 to uphold her admission and degree, setting aside the university’s withdrawal notification. The judgment emphasized fairness in academic disputes where institutional ambiguities harm students.
Procedural History:
The procedural history of the case began when Sakshi Chauhan, after being denied admission to the M.Sc. program due to changing eligibility criteria, filed Writ Petition No. 369/2021 before the Himachal Pradesh High Court. The Single Judge initially granted her interim participation in counseling but ultimately dismissed her petition on 6 March 2021, upholding the university’s decision.Sakshi then filed LPA No. 15/2021 before the Division Bench of the High Court, which stayed the Single Judge’s order and allowed her to continue studies provisionally. After she completed her degree in May 2023, the Division Bench dismissed her appeal on 19 July 2023, affirming her ineligibility.Aggrieved, Sakshi approached the Supreme Court via Special Leave Petition (Civil) No. 22269/2023, which was converted into Civil Appeal No. [X] of 2025. The Supreme Court, in its judgment dated 22 July 2025, overturned the High Court’s rulings, invoking Article 142 to validate her admission and degree, thereby concluding the litigation in her favor.
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Court Observation:
In its ruling, the Supreme Court made several key observations. It noted that the university’s repeated modifications to eligibility criteria—first permitting UGC-recognized degrees, then excluding private universities—created confusion and procedural unfairness. The Court emphasized that had the university clarified its stance earlier, the appellant could have pursued alternatives, preventing irreparable academic loss.The bench also observed that while initial ineligibility was a technical hurdle, the appellant had legitimately completed the course under court-sanctioned provisional admission, fulfilling all academic requirements. The Court criticized the university’s delayed withdrawal of her degree after two years of study, calling it arbitrary and unjust.Invoking Article 142, the Court held that denying her degree after due effort would perpetuate injustice, outweighing rigid adherence to eligibility norms. It underscored judicial discretion in academic disputes, prioritizing fairness over hyper-technicalities when institutional ambiguities harm students. The ruling thus balanced regulatory compliance with equitable relief, setting a precedent for similar cases.
Final Decision & Judgement:
The Supreme Court allowed the appeal, setting aside the judgments of the Himachal Pradesh High Court and ruling in favor of the appellant, Sakshi Chauhan. The Court held that the university’s withdrawal of her M.Sc. degree—after she had legitimately completed the course under provisional admission—was arbitrary and unjust. Exercising its extraordinary powers under Article 142 of the Constitution, the Court regularized her admission and restored her degree, declaring the university’s withdrawal notification null and void.The judgment emphasized that while technical eligibility criteria are important, they cannot override principles of fairness and equity in cases where institutional ambiguities cause undue hardship. The Court noted that Sakshi had invested two years of rigorous study, secured good grades, and fulfilled all academic requirements, making it unjust to nullify her degree retrospectively. The ruling protected her academic career while cautioning universities against retrospective disqualifications that disrupt students’ futures. No costs were awarded, and all pending applications were disposed of accordingly. The decision underscored the judiciary’s role in balancing regulatory compliance with substantive justice.
Case Details:
CASE TITLE :Sakshi Chauhan vs. Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni & Anr. CITATION : 2025 INSC 882 APPEAL NUMBER : Special Leave Petition (Civil) No. 22269 of 2023) DATE OF JUDGMENT : 22nd July 2025 BENCH : Justice B. R. Gavai & Justice Augustine George Masih
Download The Judgement Here