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 | HON’BLE MR. JUSTICE SANJAY KUMAR and HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Precedent Value | Binding authority |
| Overrules / Affirms | Affirms existing precedents on unalterable rules of the game (Mandve, Manjusree, Pathak) |
| Type of Law | Administrative law / Constitutional law (Article 14) / Educational admissions |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that once an admission process begins on defined criteria, those rules cannot be altered midstream. A prospectus with caveats that subsequent government notifications prevail does not authorize arbitrary change after applications and document submission. Mid-process changes without transparent, reasoned policy amount to arbitrariness and breach Article 14’s requirement of fairness. A representation driven by an interested party without disclosure vitiated the policy change. The existing exceptions for the COVID-19 session did not justify perpetuation of enlarged zones of consideration. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
University prospectus for MBBS/BDS 2024 limited sports credits to Classes XI–XII. After applications closed, an email and addendum allowed sports achievements from any class, benefitting certain candidates. Change followed a representation by a coach who failed to disclose personal interest. Applicants ranked lower challenged the midstream change as violative of transparency and fairness. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and admission authorities |
| Persuasive For | High Courts, other tribunals considering admission rule changes |
| Distinguishes | Ibadat Sekhon v. State of Punjab (2023 session limited exception during COVID-19) |
| Follows |
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What’s New / What Lawyers Should Note
- Reaffirms that admission norms once published and commenced cannot be altered midstream, even on government notification.
- Emphasizes transparency and reasoned policy-making to avoid arbitrariness under Article 14.
- Highlights that undisclosed personal interest vitiates any representation driving policy change.
- Clarifies that exceptions limited to one session (e.g., COVID-19 adjustments) cannot be perpetuated without fresh reasoned exercise of power.
- Lawyers can cite this decision to challenge post-application adjustments in educational and recruitment processes.
Summary of Legal Reasoning
- The “rules of the game” doctrine (Mandve; Manjusree; Pathak) bars alteration of selection criteria after process commencement.
- Prospectus caveats deferring to government notifications do not authorize arbitrary midstream change once applications close.
- Article 14 and the doctrine of legitimate expectation mandate policies be transparent, consistent, and reasoned.
- A representation by an interested third party, undisclosed and personally beneficial, invalidly influenced the policy alteration.
- The narrow COVID-19 exception (Corrigendum 01.08.2023) was session-specific and did not extend to subsequent years.
- Internal file notings tracing decision-making are relevant to expose arbitrariness and undue influence.
- Policy modification quashed; affected applicants to be re-ranked on original criteria.
Arguments by the Parties
Petitioners (Divjot Sekhon, Shubhkarman Singh, others):
- The prospectus bound all parties to sports achievements of Classes XI–XII only.
- Post-application change violated transparency, legitimate expectation, and fairness.
- Altered rankings caused loss of place in government college and higher fees in private college.
State of Punjab / University:
- Prospectus referred to imminent government notification; policy was silent on classes, permitting email clarification.
- Acts were bonafide, pursuant to Department of Sports Policy and lack of explicit statutory restriction.
- Exceptions made during COVID-19 justified broader consideration and could lawfully be continued.
Respondents (beneficiaries):
- Achievements validly submitted under clarified criteria; no procedural infirmity in their case.
Factual Background
In August 2024, Baba Farid University’s MBBS/BDS prospectus limited sports credits to Classes XI–XII. After applications closed, an email and addendum allowed sports achievements from any class, including IX–X, following a representation by a coach whose daughter benefited. Two aspirants ranked lower challenged the change as arbitrary, non-transparent, and contrary to both prospectus and the pandemic-specific exception. The High Court upheld the midstream alteration; the Supreme Court granted relief.
Statutory Analysis
- Notification dated 09.08.2024 (Government of Punjab) prescribed 1% sports quota and defers to Punjab Sports Policy 2023.
- University Prospectus Clauses 15(v) & 16(v) originally limited credits to Classes XI–XII.
- Sports Policy 2023 (Dept. of Sports) excludes sub-junior tournaments (Rule 4.2) and defines inter-se merit (Rule 5.1) without expanding classes.
- No statutory provision allowed after-the-fact expansion of the zone of consideration once the admission process began.
Alert Indicators
- ✔ Precedent Followed