Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-000067-000067 – 2026 |
| Diary Number | 44245/2024 |
| Judge Name | HON’BLE MR. JUSTICE SANJAY KUMAR |
| Bench |
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| Precedent Value | Binding |
| Affirms | The rule that selection or admission criteria cannot be altered after the process has commenced |
| Type of Law |
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| Questions of Law |
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| Ratio Decidendi | The Court held that once an admission process commences with defined criteria, alteration of those criteria midstream constitutes arbitrariness contrary to Article 14. A nodal agency (the University) cannot expand the zone of consideration for sports achievements beyond Classes XI and XII without a transparent, reasoned policy decision. A parent’s undisclosed conflict of interest vitiated the change, which was quashed as unlawful. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon by the Court | The “rules of the game” principle forbids alteration of selection criteria after commencement. Article 14 mandates fairness and non-arbitrariness in State action. Doctrine of legitimate expectation and principles of good administration require transparency and consistency. Undisclosed private interest by an influencer (parent) vitiates a policy change. |
| Facts as Summarised by the Court | Writ petitions challenged: an email and subsequent addendum that expanded sports-quota assessment from Classes XI–XII to include Classes IX–X; the change occurred after submission deadlines. Representation by a coaching parent, undisclosed conflict of interest, influenced authorities to adopt the change. The enlarged zone applied only to MBBS/BDS and not other courses, indicating arbitrariness. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All admission authorities in India; all courts |
| Persuasive For | Other State governments, universities and High Courts dealing with policy changes in admissions |
| Distinguishes | The Corrigendum dated 01.08.2023 (limited to session-2023 only) |
| Follows | Maharashtra State Road Transport Corporation v. Rajendra Bhimrao Mandve (rules-of-game principle) |
What’s New / What Lawyers Should Note
- The Supreme Court applies the “rules of the game” principle to educational admissions, prohibiting midstream changes to criteria after applications and supporting documents have been submitted.
- A policy change influenced by a representation that fails to disclose a private conflict of interest (a parent lobbying to benefit her child) is vitiated for lack of probity.
- Universities and State authorities must formulate and publish complete admission criteria—including zones of consideration for sports quotas—before commencing the process to avoid arbitrariness and nepotism.
- Doctrine of legitimate expectation mandates consistency, transparency, and predictability in admission policies; late-stage amendments breach Article 14.
- If a midstream change occurs unlawfully, relief may be limited to directly affected candidates to avoid unsettling settled admissions.
Summary of Legal Reasoning
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Admission Framework and Change
- Prospectus (09.08.2024) and Government Notification (09.08.2024) specified sports achievements in Classes XI–XII only; revised prospectus (10.08.2024) repeated the same.
- On 16.08.2024 the University emailed candidates to submit achievements from any class/year, and an addendum (03.09.2024) affirmed this.
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Conflict of Interest and Arbitrariness
- An undisclosed representation by a Roller-Skating coach and father of a respondent sought inclusion of Classes IX/X; his daughter ranked first after the change.
- The expansion applied only to MBBS/BDS, not to other courses in the same session, signaling arbitrariness.
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Applicable Legal Principles
- In MSRTC v. Mandve and subsequent decisions, criteria once published and applications invited cannot be altered mid-process.
- Article 14 requires State actions to be fair, reasonable, non-arbitrary and based on disclosed, discernible reasons.
- Legitimate expectation doctrine demands consistency and transparency in public decision-making.
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Quashing the Change
- The change was quashed as it violated the rules-of-game principle, Article 14 fairness, and was induced by undisclosed private interest.
- Remedy limited to appellants (Divjot Sekhon and Shubhkarman Singh), who were to be accommodated in government seats, with beneficiaries moved to private college seats.
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Future Policy Formulation
- State of Punjab may re-formulate policy, but must do so before commencing each admission process with clear zones of consideration.
Arguments by the Parties
Petitioners (Divjot Sekhon, Shubhkarman Singh, Agrima Mann, Gauranshi Dhingra, Navreet Singh)
- The admission criteria, as per prospectus and Government Notification, restricted sports achievements to Classes XI and XII only; midstream change was impermissible.
- The University’s email and addendum altered the criteria after the deadline, leading to arbitrariness and prejudice to genuine applicants.
- Sessions 2019, 2021, 2022 restricted to XI–XII; session-2023 expansion was a one-time COVID exception.
- They risked private-college seats at higher cost; some could have secured government seats.
State of Punjab and University
- The prospectus caveated that subsequent Government notifications would prevail; email corrected a misprint about Classes XI–XII.
- Sports policy lies with the Director of Sports; the University merely acted as nodal agency following emails and addenda.
- Cited the High Court’s decision in Ibadat Sekhon (2023 session) and representation by Sports Department endorsing permanent expansion.
- Claimed no arbitrariness, as all candidates were given opportunity to submit additional documents by 19.08.2024.
Factual Background
Between August 9 and 16 2024, Baba Farid University and the Punjab Government published admission criteria for MBBS/BDS under sports quota, limiting consideration to Classes XI and XII. On 16.08.2024, an email and later an addendum expanded eligibility to any class/year after applications closed. Two aspirants challenged the change, alleging arbitrariness and a vested interest behind it, and a third group contested its perpetuation for session-2025. The High Court dismissed all petitions, following session-2023 precedent; the Supreme Court granted relief to directly affected candidates and quashed the midstream change.
Statutory Analysis
- Government Notification (09.08.2024): Reserved 1% seats for sports quota; directed admissions on inter-se merit per sports policy—without specifying classes/years.
- University Prospectus (09–10.08.2024): Stipulated sports achievements only during Classes XI–XII; included caveat that subsequent Government notifications would prevail, and candidates should monitor updates.
- Sports Policy, 2023 (31.07.2023): Superseded 2018 policy; Rule 4.2 precluded sub-junior tournaments; Rule 5.1 dictated inter-se merit among medalists without defining zone of consideration.
- Corrigendum (01.08.2023): Temporarily for session-2023 only, expanded zone to Classes IX–X due to COVID-19—explicitly not to apply to later sessions.
Alert Indicators
- ✔ Precedent Followed – The judgment applies established “rules of the game” and Article 14 principles against midstream changes.