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 |
| Overrules / Affirms | Affirms the Supreme Court’s inherent power to grant relief where no factual dispute remains |
| Type of Law | Writ Jurisdiction / Administrative Relief |
| Questions of Law | Whether the Supreme Court can direct a university to release withheld academic records due to a bona fide clerical error when no factual dispute remains. |
| Ratio Decidendi | The Court found that the appellant was a bona fide student who had completed all semesters and whose name appeared in the primary internal record (Green Register). A clerical error in the admission disclosure list—which was not her fault—caused the delay. With no factual dispute left, relegating her to further proceedings would be unjust. The Supreme Court invoked its inherent jurisdiction to secure her substantive right to academic records and directed the university to issue the remaining marksheets and degree within four weeks. |
| Facts as Summarised by the Court | The appellant enrolled in a BA.LLB programme at Manav Bharti University (2017–2022) and cleared all semester exams. A criminal investigation led to seizure of university records. A High Court-mandated committee required a disclosure list—which mistakenly omitted her name—to verify student records. The appellant’s requests for her 5th–10th semester marksheets were denied; the university admitted the omission was a clerical error. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All educational institutions and subordinate courts in India |
| Persuasive For | High Courts handling disputes over academic document release |
What’s New / What Lawyers Should Note
- The Supreme Court will not require further factual adjudication where the university admits a bona fide administrative error and no dispute remains on record.
- A student’s lack of fault in an administrative clerical mismatch can justify immediate judicial relief under inherent jurisdiction.
- Delay caused by procedural or investigatory processes does not bar the Court from securing a student’s substantive educational rights.
- This judgment can be cited to obtain academic records when public interest litigations or internal committees leave genuine applicants without remedy.
Summary of Legal Reasoning
- Admission and Record Verification: The student’s bona fides were established by her name in the Green Register and completion of all semesters.
- Clerical Error Acknowledged: The university admitted in affidavit that her name was mistakenly omitted from the disclosure list, replaced by another student’s.
- Absence of Factual Dispute: With the admission error conceded, no further fact-finding was necessary.
- Inherent Jurisdiction: The Court invoked its inherent powers to prevent injustice and ensure the student’s right to pursue her career was not indefinitely frustrated.
- Direction for Relief: Exercising supervisory jurisdiction, the Court directed the university to issue the remaining marksheets, degree, and related documents within four weeks.
Arguments by the Parties
Petitioner (Appellant)
- She completed all semester examinations and had attendance records.
- Her name appeared in the primary internal register; omission from the disclosure list was not her fault.
- Denial of documents caused irreparable prejudice to her legal career and educational prospects.
Respondent (State / University)
- The Document Verification Committee could only verify, not correct or create records.
- The omission arose from an inadvertent clerical error by the previous administration.
- No mala fide intent; internal registers consistently showed her admission and results.
Factual Background
The appellant enrolled in the BA.LLB (2017–2022) programme at Manav Bharti University and passed all ten semesters. A police FIR and subsequent seizure of university records led to a High Court-mandated committee verifying student documents against an admission disclosure list. Due to a clerical mismatch, her name was omitted and replaced in that list, preventing issuance of her 5th–10th semester marksheets. Multiple High Court petitions and a PIL failed to secure relief, prompting this Civil Appeal.
Statutory Analysis
- Manav Bharti University was constituted under the Manav Bharti University (Establishment & Regulation) Act, 2009.
- The university is recognized under Section 22 of the University Grants Commission Act, 1956.
- No substantive statutory interpretation was required as the dispute turned on inherent judicial power and undisputed facts.
Alert Indicators
- ✔ Precedent Followed – The judgment affirms the Court’s inherent jurisdiction to grant relief where administrative errors deprive a student of academic records.