High Court Reaffirms Binding Nature of Supreme Court’s 24–25-Year Age Limit Under University Bylaws
Summary
| Category | Data |
|---|---|
| Case Name | WPMS/2468/2025 of SUMIT SINGH KARKI Vs STATE OF UTTARAKHAND |
| CNR | UKHC010128412025 |
| Decision Date | 26-08-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | Hon’ble Mr. Justice Manoj Kumar Tiwari |
| Court | High Court of Uttarakhand |
| Bench | Single‐Judge |
| Precedent Value | Binding (affirmation of Supreme Court precedent) |
| Overrules / Affirms | Affirms |
| Type of Law | Interpretation of university election bylaws and writ jurisdiction |
| Questions of Law | Whether a student over 25 years can be permitted to contest Students’ Union elections contrary to university bylaws and Supreme Court precedent |
| Ratio Decidendi | The university bylaws explicitly prohibit any student older than 25 from contesting union elections. The Supreme Court in University of Kerala v. Council, Principals’, Colleges, Kerala ((2006) 8 SCC 304) set a 24–25 age ceiling for such contests. As Supreme Court decisions are binding on High Courts under the doctrine of judicial hierarchy, this Court cannot override or relax that limit. Consequently, no relief can be granted to a petitioner seeking age‐relief beyond the prescribed maximum. |
| Judgments Relied Upon | University of Kerala (1) v. Council, Principals’, Colleges, Kerala and others ((2006) 8 SCC 304) |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | The binding nature of Supreme Court precedents; adherence to clear university bylaws; limits of writ jurisdiction. |
| Facts as Summarised by the Court | The petitioner, a student exceeding 25 years, was denied permission under university bylaws to contest the Students’ Union election of L.B.S. Government Degree College, Halduchaur, Nainital, and challenged that decision by respondent no. 4 via writ petition. |
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Practical Impact
| Category | Impact |
|---|---|
| Follows | Reaffirms (2006) 8 SCC 304 as binding on age restrictions for Students’ Union elections under university bylaws. |
What’s New / What Lawyers Should Note
- The High Court will not grant relief to candidates above 25 years, strictly adhering to Supreme Court’s 24–25 year age ceiling.
- University bylaws with unambiguous age limits prevail over writ challenges seeking relaxation.
- Reinforces that writ petitions cannot be used to contravene binding Supreme Court precedents on election qualifications.
Summary of Legal Reasoning
- The petitioner challenged the denial of age‐relaxation by respondent no. 4 for contesting the Students’ Union election.
- The Court examined the university bylaws, which categorically bar any student over 25 years from contesting.
- The Supreme Court’s decision in University of Kerala ((2006) 8 SCC 304) sets the same age ceiling for PG student elections.
- Under the doctrine of judicial hierarchy, High Courts cannot issue orders contrary to Supreme Court rulings.
- The writ petition was therefore dismissed for want of jurisdiction to override binding authority.
Factual Background
The petitioner, a student at L.B.S. Government Degree College, Halduchaur, Nainital, applied to contest the Students’ Union election but was refused age relaxation by the returning authority (respondent no. 4) on the ground that he had crossed 25 years of age. He filed WPMS/2468/2025 under Article 226 seeking quashing of the denial. The university’s election bylaws explicitly mandate a maximum age of 25, and the petitioner sought relief by way of writ jurisdiction.
Statutory Analysis
- University election bylaws provide that no student above 25 years can contest Students’ Union elections under any circumstances.
- Supreme Court’s interpretation in University of Kerala ((2006) 8 SCC 304) confirms a 24–25 age ceiling for PG student union elections.
- The inherent limits of writ jurisdiction preclude High Courts from granting relief that would conflict with binding high-court or Supreme Court precedents.
Alert Indicators
- ✔ Precedent Followed – Affirms Supreme Court decision in (2006) 8 SCC 304.
Citations
- 2025:UHC:7545
- University of Kerala v. Council, Principals’, Colleges, Kerala and others, (2006) 8 SCC 304