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Indian Institute of Technology Kharagpur v. Soutrik Sarangi

Civil Appeal · 2021 INSC 559Decided 28 Sept 2021
Civil Appeal arising out of SLP (Civil) No. 13920 of 2021
Justice Uday Umesh Lalit · Justice S. Ravindra Bhat · Justice Bela M. Trivedi

Background

Soutrik secured admission to IIT Kharagpur's Chemical Engineering program in 2020 through the JEE (Advanced) process but wanted to re-attempt JEE (Advanced) in 2021 for a different course. The IIT's eligibility rules (Criterion 5) barred any candidate who had accepted and reported to an IIT seat from reappearing for JEE (Advanced) in a later year, unlike candidates who had joined non-IIT institutions. The Calcutta High Court's Single Judge held this criterion discriminatory and arbitrary, and directed the IIT to reconsider Soutrik's case and let him register for JEE (Advanced) 2021 in the meantime. The IIT appealed directly to the Supreme Court.

Decision Breakdown

The Supreme Court held that courts must be circumspect in reviewing academic admission policies set by expert bodies and should not strike them down unless they are plainly arbitrary or discriminatory. It found that IIT seats and non-IIT seats are not comparable because an abandoned IIT seat (a scarce, nationally important public resource) cannot be refilled, whereas Criterion 5 was devised after extensive inter-institutional consultation and applied uniformly to all candidates. The Court held the High Court erred in equating the two categories and in second-guessing the IIT's admission policy, set aside the High Court's judgment, and dismissed Soutrik's writ petition, with no order as to costs.

Lesson Learnt

Courts give significant deference to the policy judgments of specialised academic institutions on admission criteria, and will not interfere unless the policy is shown to be plainly arbitrary or discriminatory: a bare claim of unfairness or hardship to one candidate is not enough.

Official source (sci.gov.in)View Judgment (PDF)

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