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Sakshi Chauhan v. Dr. Yashwant Singh Parmar University of Horticulture and Forestry

Civil Appeal · 2025 INSC 882Decided 22 Jul 2025
Civil Appeal (arising out of SLP (Civil) No. 22269 of 2023)
Chief Justice · Justice Augustine George Masih

Background

The appellant applied in 2020 for a postgraduate agribusiness programme at a Himachal Pradesh agricultural university, having completed her undergraduate degree from a UGC-recognised private university. After COVID-19 cancelled the entrance test, the university issued a series of addenda changing eligibility criteria, which retroactively disqualified candidates from private universities not accredited by the Indian Council of Agricultural Research, rejecting her candidature. She challenged this in the Himachal Pradesh High Court, obtained interim orders permitting her to join and continue the course, completed her M.Sc. over two years, and was awarded her degree in 2023, only for the High Court to later rule against her and the university to withdraw the degree.

Decision Breakdown

The Supreme Court found that except for the disputed eligibility point, the appellant had genuinely fulfilled every requirement (attendance, coursework, and examinations) over two years of study undertaken in good-faith reliance on the court's own interim orders. Taking away her degree at this late stage would cause irreparable injustice for a fault that arose from the university's own confusing, retroactively-changed criteria. Invoking its equitable powers under Article 142 of the Constitution, the Court set aside the High Court judgments, regularised her admission, and directed that her postgraduate degree be upheld.

Lesson Learnt

When a student relies in good faith on interim court orders to complete an entire course of study, the Supreme Court can use its extraordinary equitable powers to protect the resulting degree, especially where the disqualifying rule itself was introduced confusingly and after the fact.

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

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