Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-000063-000063 – 2026 |
| Diary Number | 15095/2025 |
| Judge Name | HON’BLE MR. JUSTICE AUGUSTINE GEORGE MASIH |
| Bench | HON’BLE MR. JUSTICE AUGUSTINE GEORGE MASIH; HON’BLE MR. JUSTICE VIPUL M. PANCHOLI |
| Precedent Value | Binding authority |
| Questions of Law | Whether a university must release a bona fide student’s academic documents where her exclusion from the official disclosure list was due to a clerical error. |
| Ratio Decidendi | The Supreme Court held that where a student has been admitted lawfully, has cleared all semester‐wise examinations, and her name appears in the primary internal register, she cannot be deprived of her marksheets or degree on account of a clerical mismatch in the disclosure documents sent to authorities. Administrative errors in official lists cannot be allowed to continue to prejudice an individual’s academic and professional career. The High Court’s refusal to grant relief on the ground of disputed facts was set aside because no factual controversy remained once the university admitted the error. MB University was directed to issue the 5th–10th semester marksheets, degree and other relevant documents within four weeks. |
| Facts as Summarised by the Court | The appellant enrolled in the BA.LLB (2017–2022) programme, cleared all ten semesters and received 1st–4th semester marksheets. When a SIT probe seized the university records, a verification committee was constituted, but her name was omitted from the official disclosure list due to a clerical error. Her requests to MB University and the High Court were denied, and the High Court left her to pursue fresh remedies despite admission of the mistake by the university. She approached the Supreme Court, which found no remaining factual dispute and granted relief. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All universities and higher‐education authorities |
| Persuasive For | High Courts and administrative tribunals dealing with academic records and student grievances |
What’s New / What Lawyers Should Note
- Administrative or clerical errors in official disclosure lists cannot be used to withhold academic documents from a bona fide student.
- A university’s own internal registers (e.g., green register) will prevail over mistaken external disclosures.
- Courts may grant specific performance of statutory or contractual obligations where no genuine factual dispute remains.
- High Courts should not refuse relief by relegating parties to fresh proceedings when factual issues are conclusively admitted.
- Supreme Court directions in student‐records disputes now constitute binding authority on educational institutions.
Summary of Legal Reasoning
- Admission and Examination Records: The Court noted the appellant’s admission details (Admission No. R17BALLB0033, Registration No. MBU-2017-0536) and that she cleared all ten semesters; marksheets for semesters 1–4 had been issued.
- Verification Committee Framework: A high-court-mandated committee set criteria for document release, but the appellant’s name was omitted from the official disclosure list due to a clerical error.
- University’s Admission of Error: In affidavits, MB University acknowledged the mismatch—substituting another student’s name—was inadvertent and not attributable to the appellant.
- No Factual Dispute Remains: Once the university admitted the error and the appellant’s bona fides were established, the High Court’s suggestion to pursue fresh remedies was unjustified.
- Equitable Relief: Exercising its supervisory jurisdiction, the Supreme Court directed MB University to furnish the remaining marksheets, degree and related documents within four weeks.
Arguments by the Parties
Petitioner (Appellant)
- She is a bona fide student who cleared all semesters and whose name appears in the university’s primary (green) register.
- Administrative errors in the disclosure list are not her fault; denial of documents has prejudiced her bar enrollment, higher education and career.
- High Court’s disposal forced her to run multiple proceedings over more than two years without relief.
Respondents
- State & DGP: Verification committee limited only to checking existing records; could not create or amend documents.
- MB University: Records were incomplete in the external disclosure; the committee’s mandate did not allow correction of clerical mistakes.
Factual Background
The appellant enrolled in MB University’s BA.LLB programme (2017–2022), passed all ten semesters and obtained the first four semesters’ marksheets. A SIT seized university records amid a fake‐degree probe. A High Court-appointed verification committee set criteria for document release, but the appellant’s name was omitted from the disclosure list due to a clerical error substituting another student’s name. Her requests to the university and two writ petitions failed, and a PIL was disposed of without resolving her individual claim. She then appealed to the Supreme Court.
Statutory Analysis
- Manav Bharti University was established under the Manav Bharti University (Establishment & Regulation) Act, 2009 (Himachal Pradesh).
- University Grants Commission Act, 1956, Section 22: MB University is recognized by UGC to award degrees.
- No “reading down” or “reading in” of statutes was required; relief was granted based on admitted facts and principles of equity.