Voices. Verdicts. Vision

Voices. Verdicts. Vision

Supreme Court comes to the aid of student denied Degree after completing PG Course

Sakshi Chauhan v. Dr. Yashwant Singh Parmar University of Horticulture & Forestry [Decided on 22nd July, 2025]

The Supreme Court set aside the cancellation of the postgraduate degree of a student whose admission was later questioned due to shifting eligibility criteria. The Court exercised its powers under Article 142 of the Constitution to do complete justice, holding that depriving the student of her M.Sc. degree after completing the full course would amount to irreparable injustice.

The appellant had completed her B.Sc. (Agriculture) from Eternal University, a UGC-recognized private university, and applied for admission to the M.Sc. programme at Dr. Y.S. Parmar University, Nauni, under the 2020-21 academic session. Initially considered eligible, her candidature was later rejected following a series of addendums issued by the university excluding candidates from non-ICAR-accredited institutions.

Despite being granted provisional admission and completing the M.Sc. (Environmental Management) course with good performance, her degree was withdrawn via notification dated 05.08.2023. Both the Single Judge and Division Bench of the Himachal Pradesh High Court had upheld the university’s decision, leading her to approach the Supreme Court.

The Bench comprising Chief Justice B.R. Gavai and Justice Augustine George Masih found that the university’s shifting criteria had created confusion and uncertainty. Noting that the appellant had fulfilled all academic and attendance requirements and had invested two years in the course, the Court ruled that the benefit of ambiguity must go to the student.

Invoking Article 142, the Court regularized her admission, upheld the validity of the degree conferred on May 4, 2023, and quashed the High Court’s judgments and the university’s withdrawal notification. The appeal was accordingly allowed.

Appearance: 

Appellant : Mr. Pradeep Kant, Senior Advocate with Mr. Ankur Goel, Advocate

Respondents: Mr. Sandeep Sudhir, Advocate

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