Praneeth K & Ors. v. University Grants Commission (UGC) & Ors.
Background
During the COVID-19 pandemic, the UGC issued revised guidelines on 6 July 2020 directing all universities to compulsorily hold final-year/terminal-semester examinations by 30 September 2020, even though earlier guidance had allowed flexibility. This was challenged in a batch of writ petitions (led by this one, along with several other student groups, associations, and a state government petition) arguing that forcing exams during the pandemic was unsafe, discriminatory against final-year students compared to other years who could be promoted on internal assessment, and beyond the UGC's statutory authority, especially where some State Disaster Management Authorities had separately decided it was unsafe to hold physical exams and wanted to promote students based on past performance instead.
Decision Breakdown
The Supreme Court upheld the validity of the UGC's guidelines, holding they were within UGC's statutory powers under Section 12 of the UGC Act to coordinate and maintain standards of higher education, and were not discriminatory since final-year degrees carry particular weight for future opportunities. However, the Court carved out an important exception: where a State or State Disaster Management Authority, acting under the Disaster Management Act, 2005, had genuinely decided that holding physical exams by 30 September was not feasible due to COVID-19 conditions, that decision would override the UGC's deadline for that State, though states could not simply promote final-year students without any examination at all, since that falls outside the Disaster Management Act's scope and must still give way to UGC's requirement that exams eventually be held. States wanting more time could apply to the UGC for an extension. All the writ petitions were disposed of on these terms, and a connected Special Leave Petition was dismissed.
Lesson Learnt
Education regulators like the UGC have the statutory authority to set uniform academic requirements like mandatory final-year exams even during a public health emergency, but state governments retain the power (under disaster management law) to override the timeline, though not the requirement itself, if physically holding exams would endanger public health in their state.