SCOI Restores Degree to Student After University’s Eligibility ‘U-Turn’

In a recent decision, the Supreme Court of India (2025 INSC 882, Sakshi Chauhan vs. Dr. Yashwant Singh Parmar University of Horticulture & Forestry) restored a student’s postgraduate degree, concluding a saga that underscores the critical importance of clarity and consistency in university admission processes.

What's The Matter?

Sakshi Chauhan, a B.Sc. Agriculture graduate from Eternal University (a UGC-recognized private institution), sought admission to a postgraduate program at Dr. YSP University. With COVID-19 upending the usual admission routine, the university cancelled entrance exams and opted to assess students based on undergraduate marks a process, it seemed, that would rely on the criteria listed in the original prospectus: a bachelor’s degree from a UGC-recognized university.

However, as the months progressed, the university issued a series of notices and last-minute addenda. What began as a straightforward eligibility condition UGC recognition morphed into a requirement for ICAR accreditation, effectively disqualifying candidates from private universities like Sakshi’s, despite prior official recognition.

The Changed Elgibility Criteria led Sakshi and others in a state of uncertainty. By the time the university finally clarified its stance, candidates had missed the window to consider alternatives.

Sakshi, provisionally admitted by court order, completed her course and received her degree, only to have it suddenly rescinded after two years of academic effort.

What Happened in Court?

Sakshi challenged the cancellation in the Himachal Pradesh High Court, which inclined with the New Eligibility Criteria. The reasoning was technical: since her B.Sc. was from a non-ICAR-accredited institution, she was ineligible, regardless of her performance or that the university had previously admitted her under shifting conditions.

It was only before the Supreme Court that Sakshi found relief.

The bench recognised that, while there may have been technical ambiguity about her eligibility, the university’s own evolving criteria and lack of timely communication had set the stage for confusion and hardship.

Court was of the view that universities hold a responsibility to ensure their eligibility criteria are precise, public, and stable.

When institutions fail in this duty, students are the ones who pay the price their education, career prospects, and trust put at risk through no fault of their own. The Court observed that, had the original rules been clear or changes communicated up-front, students like Sakshi could have sought admission elsewhere and avoided a wasted investment of time and resources.

Importantly, the Court emphasized that degrees from UGC-recognised universities must carry weight unless expressly excluded in advance not after the fact.

Technicalities, it underlined, should not override principles of justice and fairness when someone has already complied with academic rigor and invested significant effort.

Balancing these considerations, the Supreme Court invoked its extraordinary powers under Article 142 of the Constitution to ensure “complete justice.”

The judgment expressly required the university to restore and regularize Sakshi’s degree, setting aside previous High Court orders and declaring the university’s retrospective withdrawal of her qualification “otiose.”