The Supreme Court has regularized the admission of a student to M.Sc. Environmental Management course and asked Dr. Yashwant Singh Parmar, University of Horticulture & Forestry in Himachal Pradesh, to confer the candidate with a postgraduate degree. The Apex Court noted that there appeared to be some confusion even at the end of the University, which required clarity at different stages.

The Appeal was filed by a candidate who had fulfilled the course curriculum, including the minimum required attendance.

The Division Bench of Chief Justice Of India B. R. Gavai and Justice Augustine George Masih said, “There appears to be some confusion even at the end of Respondent No. 1 University requiring clarity at different stages, which is apparent from the Notice dated 03.12.2020, amendments through addendum in Chapter 3 of the Prospectus on 11.12.2020, and the addendum dated 15.12.2020, wherein at each stage, some additions were made with regard to a candidate being eligible or not for consideration for admission. Under these circumstances, the benefit should go to the Appellant, especially when she had completed her course with good marks by investing two years of hard work.”

AOR Chritarth Palli represented the Appellant while AOR Vikrant Narayan Vasudeva represented the Respondent.

Factual Background

In pursuance of the Prospectus issued in May 2020 by Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni, Solan, HP (Respondent 1), the appellant sought admission in M.Sc/MBA (Agri Business Programm) for the Academic Session 2020-21. The appellant applied in pursuance of the said Prospectus, having passed the Bachelor of Science (Hons.) in Agriculture in 2020 from a private university, which was affiliated/recognized by the University Grants Commission (UGC).

The Respondent University put up a notice pointing out that the candidates who had passed their B.Sc. degree from non-State Agricultural Universities/Central Agriculture Universities/ Central Universities (SAUs/CAUs/CUs) with Agriculture faculty, in accordance with the prescribed minimum qualification, were not eligible for allotment of seats in the M.Sc. program. Addendum was carried out in the prospectus. Since the Appellant had passed her B.Sc. Agriculture from a non SAUs/CAUs/CUs facility, she was declared non-entitled for allotment of seats in the M.Sc. programm. The Appellant approached the Himachal Pradesh High Court by filing a writ petition.

Meanwhile, the Appellant, in pursuance of the said provisional admission, proceeded to complete her course and was awarded the degree. The appeal before the Division Bench came to be dismissed, upholding the judgment passed by the Single Judge whereby it was held that the Appellant was ineligible for admission to Respondent University, having passed her B.Sc. (Agriculture) from a private University. This led to a challenge to the said judgment by way of the appeal.

Reasoning

The Bench noted that there was some confusion even at the end of the Respondent University, requiring clarity at different stages. As per the Bench, the benefit should have gone to the Appellant, especially when she had completed her course. It was also noticed that except for the initial ineligibility i.e., having passed her B.Sc. Agriculture from the private university, which was also admittedly recognized by the UGC, the Appellant fulfilled the other eligibility criteria.

She had also passed the relevant papers after fulfilling the course curriculum, including the minimum required attendance etc. “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”, it held.

Thus, exercising jurisdiction as conferred under Article 142 of the Constitution of India, the Bench regularized the appellant’s admission to the M.Sc. Environmental Management course and upheld the conferring of the postgraduate degree. Allowing the appeal, the Bench set aside the impugned judgments and ordered, “The Appellant shall be conferred with degree as completed by her in accordance with due process by Respondent No.1 University.”

Cause Title: Sakshi Chauhan v. Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni & Anr. (Neutral Citation: 2025 INSC 882)

Appearance

Appellant: AOR Chritarth Palli

Respondent: AOR Vikrant Narayan Vasudeva

Click here to read/download Judgment


Chief Justice of India B. R. GavaiJustice Augustine George Masih

Tulip Kanth

Assistant Editor

Tulip Kanth is an Assistant Editor at Verdictum having over 5 years of experience in the field of legal journalism and editing. She extensively covers judgments of the Supreme Court, High Courts as well as Tribunals. She has previously worked with a legal publishing website where she oversaw the work of other editors and has also created updates on notifications of different Government Ministries. She holds an English Honours Degree from SGTB Khalsa College, Delhi University and has completed her LLB course with specialisation in Corporate Law from Amity University.