S. Gunasekaran vs The Under Secretary to Govt. and Others
Background
The appellant was allotted an M.D. (Endocrinology) seat in the first round of medical counselling for 2022-23 and joined the course, but was not upgraded in the second round and resigned from his seat within two days of the second-round results, as permitted under the prospectus rule then in force. However, the prospectus was amended midway through the admission process, removing that specific exit option, and the college and authorities disputed when they were actually informed of his resignation. The college invoked a penalty clause demanding Rs.30 lakh from the appellant and withheld his academic documents.
Decision Breakdown
The Supreme Court found that the appellant's resignation complied with the original prospectus rule in force when he made his decision, and that the confusion arose because the authorities changed the rules midway through the admission process without adequate diligence in finalising the prospectus before the process began. While holding the appellant partly responsible for not checking the updated prospectus, the Court found the authorities equally at fault for allowing an avoidable seat wastage. Taking a practical, case-specific approach (and noting the respondent college's own graciousness in not insisting on the full penalty), the Court reduced the appellant's liability to the amount he had already deposited (about Rs.4.06 lakh) instead of the demanded Rs.30 lakh, and directed release of his documents within two weeks, clarifying the order was not to be treated as a precedent.
Lesson Learnt
When a public authority changes admission rules midway through a process and this creates genuine confusion for a candidate acting in good faith on the original rules, courts can moderate penalties to reflect shared responsibility rather than placing the entire burden on the candidate.