In a landmark decision, the Supreme Court of India on 22July 2025, gave a ruling in a case, Sakshi Chauhan v.Dr. Yashwant Singh Parmar University of Horticulture & Forestry that confirmed the post graduate degree of an appellant who was initially found to be not eligible to be given admission. The case under Civil Appeal No. OF 2025 (@SLP (CIVIL) NO. 22269 OF 2023) raises some important questions on the aspects of admission eligibility, the manner in which the prospectus clauses can be interpreted and how the inherent powers of the apex court can be used to do full justice. The judgment is a good test case and has significant lessons on how the ambiguity of procedures and what one proceeds to do may affect what one may achieve on the academic front.
Case Facts: The Story of Varying Standards
The appellant is Sakshi Chauhan who had applied in the M.Sc/MBA (Agri Business Programme) in the Academic Session 2020-21 at Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni (Respondent No.1). She had also pursued Bachelor of Science (Hons.) in https://www.google.com/search?q=Agriculture in the year 2020 through Eternal University, Baru Sahib, Sirmour, HP (Respondent No.2), which is a private university that was recognized by the University Grants Commission (UGC).
First, in May 2020, the prospectus issued by Respondent No.1 suggested an entrance examination to be used during admissions. Owing to COVID-19 pandemic, this test has been cancelled and a merit list shall be developed based on Overall Grade Point Average (OGPA) or marks of qualifying degree and other weightages as prescribed. No change in the minimum requirements to be eligible as mentioned in the prospectus of May 2020. The appellant submitted an application to be admitted in May 2020, and the application was kept under processing; however, the claim is that it was not rejected, and that it met all the requirements of the admission.
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The problems occurred through the further notices and addendums made by Respondent No.1. On December 3, 2020, a new notification claiming that B.Sc. (Non-SAUs/CAUs/CUs) candidates with a faculty https://www.google.com/search?q=Agriculture in B.Sc. in any discipline with agricultural faculty would not be able to obtain M.Sc. It is also said that applicants with B.Sc. (Non-SAUs/CAUs/CUs) degrees in any subject related to agriculture with an agricultural faculty would not be able to obtain an M.Sc. An addendum issued on December 11, 2020 then amended Chapter 3 of the Prospectus that not only candidates of agricultural non-ICAR accredited private universities/colleges, but also those affiliated to public-funded institutions, were not eligible. This ineligibility in terms of having 4-year B.Sc. graduates in Horticulture/Forestry/Agricultural/Food Technology degree holders based in ICAR non-accredited private universities was put in further addendum on December 15, 2020.
Due to these changing criteria, the appellant was notified that she would not be considered eligible, her application was rejected and she could not get entry into this course on the basis of her cleared B.Sc. https://www.google.com/search?q=Agriculture because she had studied through a non-SAUS/CAUS/CUs facility even though she had graduated through a UGC recognised university.
The High Court challenge of the law
Disappointed by this variable eligibility and her nomination as a candidate being rejected, the appellant moved the High Court of Himachal Pradesh in form of a writ petition (CWP No. 369/2021). She opposed the shift in the criteria and expected the Respondent No. 1 University to allow her to gain an admission to the M.Sc. cite_start program on merit basis.
On January 27, 2021, the Single Judge, who had the benefit of perusing the order passed by the Single Judge on January 8, has passed an interim order by which he has permitted the appellant to attend the counseling, subject to the understanding that the participation of the appellant does not confer any right and is conditional upon the final decision of the writ petition. Later on the appellant was provisionally admitted to complete a course in M.Sc. Environmental Management in a self-finance seat, which she did.
It was however held by the learned Single Judge in the writ petition that the appellant was not deserving of admission to Respondent No.1 University on the basis that she had acquired her B.Sc. cite_rad degree in a private university (Respondent No. 2) and dismissed such writ petition. The court made no adverse comment on her quality or in other elements of her candidature.
Thereafter, the appellant made an intracourt appeal (LPA/No 15/2021). The Division Bench, by order dated March 15, 2021, temporarily stayed the finding by the learned Single Judge, and by order dated April 19, 2021, required the University, being Respondent No. 1 to it, to allow the appellant to provisionally continue her course of study and attend lectures in the nursing course she passed, M.Sc. in Environmental Management.
In furtherance of this provisional admissions, the appellant proceeded with her course and was given the degree on May 4, 2023. Nevertheless, the Division Bench ended up rejecting her appeal on July 19, 2023, claiming that the judgment of the Single Judge will also stand. It gave rise to the present appeal to the Supreme Court.
Supreme Court Arguments
According to the argument of the counsel of the appellant, the original prospectus and other clarifications or addendums to it, were very confusing and riddling of certainty in the process of admission. Had the prospectus been clear at the very beginning, her application should have been denied on the spot, so that she can apply to some other institute. The delay due to the changing requirement and the unbelievable delay in the admission process and after the decision on basing the admissions on the graduation merit was highlighted.
More importantly, the counsel of the appellant also argued that the grant of admission and the successful completion of the course by the appellant resulting in conferment of a postgraduate degree, its subsequent removal in terms of a notification dated August 5, 2023, and cancellation by Respondent No. 1 University cannot be held sustainable. It was pointed out that the first eligibility criteria was not explicit regarding the exclusion of the privately educated candidates. The prospectus as per the appellant wrote that a B.Sc. degree of a UGC-recognised university is adequate and her degree at Respondent No. 2, which admittedly was UGC- recognised also satisfied it.
It was argued further that the exercise of powers under Article 142 of the Constitution of India should be done to render entire justice as withdrawal of her degree would be irreparable.
On the other hand, the counsel to Respondent No. 1 University favoured the judgments made by the High Court and insisted that the appellant was not qualified under the original criteria used in the prospectus and therefore the amendment of the prospectus had no consequence to her application. Once having been admitted provisionally and found ineligible the candidate could not as a matter of course have the degree, they argued, on successful completion of his course. The university however did not argue that the appellant had attended to the attendance and other requirements of the course and had taken the exams and had performed well with the only dispute being her lack of eligibility to make it in the first place.
Principle of Total Justice and the Verdict of the Supreme Court
After reading the submissions and the impugned judgments, the Supreme Court accepted that the candidature of the appellant may not have been the one that distinctly fell into the segment of eligible category under Clause 3.1 of the May 2020 Prospectus.
Nevertheless, the Court recorded how Respondent No. 1 University was apparent in its confusion as it exhibited in the notice dated December 3, 2020, followed by addendums with additional conditions of eligibility dated December 11, 2020, and December 15, 2020. It was based on such a situation that the Court opined in favor of the appellant being granted of the benefit, particularly, given the fact that she had passed her course with commendable grades and had dedicated two years of her life into the course.
The Court underlined that there was only one uncontested ineligibility due to her B.Sc. https://www.google.com/search?q=Agriculture was of a private institution but then the UGC had recognized it. Her having a graduation degree, and having passed all course requirements including attending the course and passing the examinations with good marks were not argued about.
The Supreme Court was of the opinion that it would not be appropriate at this stage to deprive the appellant of her degree and this would be unjust to her and it will result in irreparable loss to her career. Hence, this was a right case to exercise jurisdiction under Article 142 of the Constitution of India, to award full justice by the Court.
The Court retained the awarding of the post graduate degree upon her on May 4, 2023 and ordered a regularization of her admission into the M.Sc. Environmental Management course. As a result, her degree withdrawal notification of August 5, 2023, became worthless.
The orders given by the Single Bench as well as the division bench of the high court of Himachal Pradesh were quashed. The Supreme Court instructed Respondent No.1 University to award the appellant the degree officially and in due process.
The importance of this case as a precedent occurs through the ruling of the Supreme Court in the case of Sakshi Chauhan because the judiciary, despite the administrative ambiguities and the procedural errors arose, played a very vital role in reducing the negative impact it may have when a party which acted innocently had spent much time and effort. The case brings out the need of explicit and uniform admission standards on the part of educational institutions and, more importantly, sufficient consideration of Article 142 to avoid wasting of irreparable injuries and full justice. It reinforces the message that although eligibility is the most important thing, the final goal of the legal system is to reveal fairness and avoid excessive problems caused by misunderstandings or ignorance.
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