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Education LawSupreme Court of India

Anand Sheshman Patel v. The Registrar, North Maharashtra University

Civil Appeal · 2025 INSC 722Decided 7 May 2025
Civil Appeal (arising out of SLP(C) No. 29516 of 2024)
Justice B.R. Gavai · Justice Augustine George Masih

Background

The appellant, claiming to belong to the Kunbi caste (OBC category), was admitted to a B.Tech programme against an OBC-reserved seat, and his caste certificate was sent for verification in 2015. When the Scrutiny Committee failed to decide the claim for years, he was forced to approach the Bombay High Court, which in 2020 directed a decision and awarded him costs against the Committee members for their inaction. His caste claim was eventually invalidated, and when the university then withheld his mark-sheets and degree certificate, his fresh writ petition before the Aurangabad Bench of the High Court was dismissed.

Decision Breakdown

The Supreme Court noted that the Scrutiny Committee's own unreasonable delay had forced the appellant to litigate for years, and that the High Court had already recognised this and penalised the Committee members. Given that the appellant had, in the meantime, completed his entire course of education, the Court held that his education deserved to be protected and directed the university to release his mark-sheets and degree certificate within four weeks. It clarified, however, that he would not be entitled to any benefits reserved for OBC candidates going forward, since his caste claim had been invalidated, and expressly stated the order was passed on the peculiar facts of the case and was not to be treated as a precedent.

Lesson Learnt

Where a government scrutiny body's own prolonged inaction forces a student into years of litigation, courts can step in on equitable grounds to ensure the student is not permanently deprived of an education already completed, even while confirming that the underlying reserved-category claim itself was rightly rejected.

Anand Sheshman Patel v. The Registrar, North Maharashtra University – Legal Case Shots | LegalAware