The Delhi High Court has held that the new regulatory regime replacing the M.Phil. (Clinical Psychology) pathway cannot be applied to students who were already pursuing B.A./B.Sc. in any stream, or M.A. in Psychology/Clinical Psychology, or had completed M.A. (Clinical Psychology) in 2026 under the earlier UGC framework, because they had enrolled with a legitimate expectation of progressing to M.Phil. and RCI registration. Applying the new regime to this cohort without a proper transition would be arbitrary, inequitable, unfair, and amount to retrospective deprivation of an accrued academic and professional pathway.
The Court therefore drew a clear distinction between existing students and future students. It held that the new regime would apply to Class XII students entering under the new policy, but not to the protected cohort already within the earlier academic stream. The Court noted that despite its earlier order dated May 05, 2026 in W.P.(C) 2399/2026, UGC and RCI had not taken steps to recommence the M.Phil. programme, which led the petitioners to approach the Court again.
Accordingly, the Court directed respondent nos. 1 and 2, namely UGC and RCI, to issue an appropriate clarification or public notice within four weeks stating that the new regime would not apply to students covered under the earlier regime, specifically those presently pursuing B.A./B.Sc. (any stream) and M.A. (Psychology) under the UGC framework. The Court further directed UGC and RCI to take steps to recognise, recommence, or continue the M.Phil. (Psychology) programme for students pursuing B.A./B.Sc. (any stream/discipline) and M.A. (Clinical Psychology) under the UGC framework, beginning from August 2026 for the academic session 2026-2027, and to ensure continuity of the course for as long as required for such students.
A Single Judge Bench of Justice Jasmeet Singh closely examined the old and new academic pathways and found that students who were already pursuing B.A./B.Sc. in any stream or M.A. in Psychology had entered those courses on the basis of an existing pathway that allowed progression to M.Phil. (Clinical Psychology) and then RCI registration. The Court observed that there was no difficulty in applying the new regime to future Class XII students, but the real problem arose for the transitional cohort already in the system.
The Court held that under the new structure, such students would be compelled to go back and repeat undergraduate and postgraduate studies in Clinical Psychology before becoming eligible for RCI registration. It treated this as an excessive academic burden and a serious disruption of the continuity of their education. Referring to its earlier reasoning in Prabhroop Kaur Kapoor v. Union of India [WP (C) 15086/2025], the Court reiterated that while courts generally do not interfere in education policy, judicial intervention is justified where the issue concerns interpretation, application, or enforcement of a policy that operates arbitrarily or retrospectively to the detriment of students who had already acted on the earlier regime.
The Court found that the petitioners had a legitimate and well-founded expectation that, after enrolling in their existing courses, they would be able to proceed to M.Phil. (Clinical Psychology) and thereafter obtain RCI registration. The sudden application of the new regime without a workable transitional mechanism was therefore held to be manifestly unreasonable, disproportionate, and a retrospective withdrawal of a valuable right that had already accrued to them by virtue of their enrolment under the earlier regime.
Briefly, a petition was filed by students who had pursued, or were pursuing, M.A. in Clinical Psychology after completing B.A. in a different discipline, and who claimed they had been left without a workable career path because the M.Phil. (Clinical Psychology) programme had been discontinued. The petitioners sought directions to protect students falling within the same transitional category already identified by the Court in its earlier order dated May 05, 2026 in W.P.(C) 2399/2026.
The UGC, pursuant to NEP 2020, notified the Ph.D. Regulations, 2022, and Regulation 14 barred higher educational institutions from offering M.Phil. programmes. This resulted in discontinuation of the M.Phil. route in Clinical Psychology without a simultaneously notified harmonised replacement pathway for regulated mental health disciplines.
In inter-ministerial meetings held in 2023, a replacement framework was identified, including two alternative pathways: one through allied professions via four-year specialised undergraduate programmes, and another through a general academic route of four-year undergraduate plus two-year master’s programmes. The minutes also noted that existing M.Phil. courses ought to continue for five to six years in parallel so that disruption to the mental health workforce could be avoided, though later the earlier M.Phil. programme was extended only for two years.
The UGC notice dated Jan 30, 2024 effectively discontinued the earlier regime from the academic session 2025-26, under which candidates from different streams could pursue M.Phil. in Clinical Psychology. The petitioners argued that under the new framework, students who had lawfully entered the old academic route were being forced either to repeat undergraduate studies or re-enter new programmes, leading to duplication of education, uncertainty in registration pathways, and unequal academic burdens.
