Ms. Navya Sharma & Anr. vs University Grant Commission & Ors.

$~79
* IN THE HIGH COURT OF DELHI AT NEW DELHI

Date of Decision: 06.07.2026

+ W.P.(C) 8560/2026
MS. NAVYA SHARMA & ANR. .....Petitioners
Through: Ms. Pragya Narayan, Adv. Manuraj
Pillai, Advs.
versus
UNIVERSITY GRANT COMMISSION & ORS. .....Respondents
Through: Mr Parmanand Gaur SC for UGC
with alongwith Mr. Vibhav Mishra and Ms.
Megha Gaur Advocates
Adv Vinay Kaushik, GP
Ms. Radhika Bishwajit Dubey, CGSC Ms. Gurleen
Kaur Waraich, Adv Mr. Kritarth Upadhyay, Adv
Mr. Amulya Dev Mishra, Adv for R3
Mr Amitesh Kumar Ms. Priti Kumari, Advs. for
R4
CORAM:
HON'BLE MR. JUSTICE JASMEET SINGH

: JASMEET SINGH, J ( ORAL )

1. The present matter is almost covered by a previous judgment/Order of
this Court dated 05.05.2026 passed in W.P.(C) No. 2399/2026. In view of that
judgment/Order and using the same reasons and expressions, this Order is
being passed.
2. This is a writ petition filed under Article 226 of the Constitution of
India seeking the following prayers:-
“a) Issue an appropriate writ, order or direction directing
the Respondents to recommence, permit or otherwise
facilitate admissions to the M.Phil. (Clinical Psychology)
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programme within a time-bound period, for Petitioners and
other students belonging to the protected cohort identified by
this Hon'ble Court in its judgment dated 05.05.2026;
b) Issue an appropriate writ, order or direction declaring
that the Petitioners, being students covered by the judgment
dated 05.05.2026 passed in W.P.(C) No. 2399/2026, shall not
be denied an opportunity to pursue professional qualification
and registration as Clinical Psychologists merely on account
of the discontinuation of the M.Phil. (Clinical Psychology)
programme;
c) Issue an appropriate writ, order or direction directing the
Respondents to ensure that students covered by the judgment
dated 05.05.2026 are not compelled to undertake a fresh
four-year undergraduate degree in Psychology or otherwise
retrace their academic journey as a condition for pursuing
professional qualification and registration in Clinical
Psychology;
d) Issue an appropriate writ, order or direction directing
Respondent No. 1 and Respondent No. 2 to forthwith issue an
appropriate public notification, circular and/or clarification,
in compliance with the Judgment dated 05.05.2026 passed by
this Hon'ble Court in W.P.(C) No. 2399/2026, MAN Mental
Health Awareness and Networking Society v. Rehabilitation
Council of India & Ors., clearly declaring that the new
regulatory regime shall not apply to students belonging to the
protected cohort identified therein and specifying the
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transitional mechanism and academic pathway available to
such students for obtaining professional qualification and
registration as Clinical Psychologists.
e) Pending disposal of the present Writ Petition, direct the
Respondents to reserve and/or create appropriate seats in the
M.Phil. (Clinical Psychology) programme within a specified
time-frame, for students covered by the judgment dated
05.05.2026, including the Petitioners herein;...”

3. The brief facts of the case are that the petitioners are students who have
M.A. (Clinical Psychology) Programme after completing B.A. in other
discipline and have been rendered pathless due to discontinuation of M. Phil.
Programme.
4. The respondent No. 1 is the University Grants Commission (“UGC”) ,
which oversees the standards of higher education. The respondent No. 2
namely, the Rehabilitation Council of India ( “RCI” ) is the statutory body
regulating rehabilitation education and maintaining a central register of
qualified professionals. The respondent No. 3 is the Department of Higher
Education, Ministry of Education and the respondent No. 4 is the Amity
University, Noida.
5. Pursuant to NEP 2020 respondent No. 1, notified PhD regulations 2022
and by Regulation 14 prohibited higher educational institutions from offering
M.Phil programmes resulting in discontinuation of M.Phil in Clinical
Psychology and psychiatrist social work, without simultaneously notifying a
harmonised professional replacement pathway for regulated mental health
disciplines. Regulation 14 reads as under:-
“14. Grant of M.Phil. Degree.- Higher Educational Institutions
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shall not offer the M.Phil.(Master of Philosophy) programme.”

6. On 01.06.2023, an inter-ministerial meeting was convened by the
Ministry of Health and Family Welfare and follow up meetings were held. On
29.08.2023, in the inter ministerial meeting the finalized replacement
framework for discontinued M.Phil programme was identified with two
alternative academic pathways which read as under:-
“(i) Allied Professions (four-year B.Sc. (Hons.) Clinical
Psychology and B.A. (Hons.) Psychiatric Social Work to be
regulated by Respondent No.4), and
(ii) General Academic (four-year undergraduate plus two-year
master’s programmes to be regulated by Respondent No.1),
with provision for practical training, PG-Diploma exit options”
7. The minutes recorded that existing M.Phil courses ought to be
permitted to be continued for next five to six years in parallel with the newly
proposed track to prevent disruption of the workforce in the mental health
centre. The operative portion of the minutes reads as under:-
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8. Subsequently, the earlier M.Phil programme was extended for the two
years.
9. On 30.01.2024, the UGC released the notice dated 30.01.2024, which
reads as under:-
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10. A perusal of the notice shows that the earlier regime of candidates
coming through various streams and getting an M.Phil degree in Clinical
Psychology was discontinued from 2025-26 academic session.
11. Learned counsel for the petitioner challenges the same and urges the
petition on the following grounds:-
“ i. Students who have completed or are presently pursuing
M.A. Clinical Psychology under UGC-regulated universities
are now compelled to again undertake an RCI-regulated M.A.
programme in order to become eligible for registration in the
Central Rehabilitation Register.
ii. Candidates who enrolled in B.A. programmes in allied or
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non-psychology disciplines, who were earlier eligible to pursue
M.A. Clinical Psychology, are now rendered ineligible under
the new framework.
iii. Graduates who earlier lawfully completed a B.A. in another
subject followed by an M.A. in Clinical Psychology are barred
from entering the RCI-regulated pathway, even though their
qualifications were previously recognised.
iv. Science-stream students are permitted to reach certain level
of registration under CRR through a four-year B.Sc. (Clinical
Psychology) pathway, whereas Humanities-stream students are
required to undergo a substantially longer route of B.A. plus
M.A., thereby imposing an unequal academic burden.
v. The continued operation of identically titled “M.A. Clinical
Psychology” degrees under both UGC and RCI, without
discontinuing or harmonising the UGC-regulated programme,
is likely to mislead students, employers and the public.
vi. Under the earlier regime, the M.Phil (Clinical Psychology)
was an advanced professional qualification above the master’s
level. In the new regime, the replacement of the M.Phil with an
M.A. of the same duration and title lowers the perceived
academic standing of the qualification and is likely to adversely
affect graduates’ prospects both within India and abroad.
vii. The new regime is also silent with respect to any
higher-level degree, namely, M.Sc for the B.Sc graduates. It
also does not confirm if the new M.A. course in the General
Academic route is open for the B.Sc students.
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viii. Graduates who, under the earlier regime, had completed a
B.A. in a discipline other than Psychology followed by an M.A.
in Clinical Psychology are now rendered ineligible for
registration under Respondent No.1.
ix. The introduction of additional undergraduate psychology
programmes, including the newly notified four-year Bachelor
of Psychology (B.Psy) course under Respondent No.4/NCAHP,
alongside the B.Sc. (Clinical Psychology) course and the
B.A./M.A. route regulated by Respondent No.1, has multiplied
parallel entry routes into the profession without any certainty
with respect to scope of practice or eligibility for registration.
x. The creation of parallel undergraduate pathways has
generated uncertainty as to which qualifications will ultimately
permit registration in the Central Rehabilitation Register.”
12. Since the guidelines were issued by the respondent No. 2 in terms of
the new policy, the present petition has been filed.
13. My attention has been drawn to the entry requirement which is as
under:-
“Entry requirement
Minimum educational requirement for admission to this course
will be 4 years B. A./B.Sc. degree in Psychology from a
university recognized by the UGC with a minimum of 55% marks
in aggregate. For SC/ST category, minimum of 50% marks in
aggregate is essential, as per GOI. The candidates who have
completed their graduation programme in 3 years shall have to
pass fourth year Bridge Course or first year of Masters
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Programme in Psychology with minimum of 550/, marks are also
eligible.”
14. I have heard learned counsels for the parties.
15. The following tables are relevant to show the old regime and the new
regime:
UNDERGRADUATE STUDENTS
TABLE III
UNDERGRADUATE STUDENTS- B.A/B.Sc. (Any stream/discipline
other than Psychology) under UGC
Education Level Earlier Position
(Pre-NEP/Old
Regime)
Present Position under
RCI (Impugned
Framework)
Undergraduate
B.A./B.Sc in any
stream/discipline other
than Psychology under
UGC
(completed/ongoing)
B.A./B.Sc in any
stream/discipline other
than Psychology under
UGC
(completed/ongoing)

Post-graduate Eligible for admission
in M.A. (Psychology)
under UGC
Not eligible for
admission in M.A.
Clinical Psychology
Constrained to enroll
again in
undergraduate course
of B.A. in Psychology
under UGC (4 years)
/B.Sc in Clinical
Psychology (4 years)
under RCI
Masters in Philosophy M. Phil (Clinical
Psychology)

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RCI Registration
(3+2+2=7 years for
RCI)
RCI registration
pathway only after
repeating
undergraduate studies
through a fresh 4-year
B.A. in Psychology
under UGC/B.Sc. in
Clinical Psychology
under RCI followed by
M.A. (Clinical
Psychology), resulting
in duplication of
education and an
excessive academic
burden:
3 years (existing UGC
undergraduate
degree) – not
recognised
+
4 years fresh B.A. in
Psychology under
UGC/B.Sc. Clinical
Psychology under RCI
+
2 years M.A. (Clinical
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Psychology) = 9 years
of RCI
Registration
Note: B.Sc (Clinical
Psychology) student
under RCI would still
not be able to pursue
M.A. (Clinical
Psychology) or any
other course to become
Clinical Psychologist –
only RCI Registration
as ‘Clinical Assistant’


POSTGRADUATE STUDENTS
TABLE IV

STUDENTS WHO HAVE ALREADY ENROLLED/COMPLETED
B.A. (ANY STREAM OTHER THAN PSYCHOLOGY) M.A.
(PSYCHOLOGY, CLINICAL PSYCHOLOGY AND OTHER
BRANCHES OF PSYCHOLOGY)
(UGC REGULATED)
Education Level Earlier Position
(Pre-NEP/Old
Regime)
Present Position under
RCI (Impugned
Framework)
Post graduate completed
under UGC
B.A./B.Sc. (any stream
other than Psychology)
+ M.A. (Psychology,
B.A./B.Sc. (any stream
other than Psychology)
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Clinical Psychology and
other branches of
Psychology) (on
going/completed)
under UGC
+
M.A. (Psychology,
Clinical Psychology and
other branches of
Psychology)
UGC Regulated
Valid and recognized
for RCI registration post
completion of M.Phil
(Clinical Psychology)
(ongoing/completed)
UGC Regulated
Not recognised for RCI
Registration
Masters in Philosophy M. Phil (Clinical
Psychology)
M.Phil pathway
abolished

Constrained to enroll
again in undergraduate
course of B.A. in
Psychology under
UGC/B.Sc. in
Psychology (4 years)
under RCI.




After BA in
Psychology, again
constrained to enrol in
M.A. Clinical
Psychology for RCI
Registration.








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RCI Registration
3 years (existing
B.A./B.Sc.)
3 years B.A./B.Sc (any
stream) + 2 years
+
M.A. (Clinical
Psychology) under
UGC + 2 years M.Phil
(Clinical Psychology) 7
years (earlier recognised
pathway)
Ongoing 2 years M.A.
(Clinical Psychology)
under UGC
+
4 years B.A./B.Sc
Psychology under UGC
+
2 years M.A. (Clinical
Psychology)
11+years for RCI
Registration to become
Clinical Psychologist

16. A perusal of the above tables shows that a student in B.A and B.Sc
could go for M.A Psychology and obtain a degree in M.Phil (Clinical
Psychology). There can be no ambiguity as far as student studying in class XII
are concerned to take the new regime in accordance with the NEP 2020. The
problem lies with students (presently the petitioners) who are pursuing B.A.,
B.SC in any stream or pursuing M.A Psychology. The said candidates now
cannot proceed to go for M.Phil (Clinical Psychology) and obtain RCI
registration.
17. The students who are undergoing B.A., B.SC in any stream/ discipline
today or are undergoing M.A Psychology will have to go back to B.A., B.Sc
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and M.A in Clinical Psychology and thereafter get RCI registration for
pursuing a profession in Clinical Psychology.
18. A similar kind of situation has been considered in WP (C) 15086/2025
Prabhroop Kaur Kapoor v. Union of India and more particularly in para 46
to 51, which reads as under:-
“46. The petitioners constitute a limited category of students
who had already acted upon the prevailing policy. Denying
the facility results in serious and irreversible prejudice to the
petitioners, who have already invested an academic year in
preparation based on a legitimate expectation.
47. The law laid down in Surender Kumar Dhawan (supra) is
also binding upon this Court that in questions of education
policy and academic matters the Courts are to refrain from
interfering. However, the said judgement also holds that if
any provision or principle of law is to be interpreted, applied
or enforced with reference to or connected with education,
the Courts are required to step in. 9 This Court is neither
required to nor is going into the legality, justifiability or the
basis which has prompted/ necessitated the amendment to the
examination policy. However, this court, in the present case,
is concerned with interpretation, application and
enforcement of amendment to Clause No. 43 (i) of Bye Laws
only to the graduates of Class XII of 2025 batch, which is
working to the detriment of the petitioner and is seeking to
retrospectively withdraw a valuable vested right. The
applicability was abrupt and thus, when the actions are
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arbitrary and unreasonable, it is imperative to intervene in
such a case.
48. CBSE’s submission that no prejudice is caused since
students may appear through NIOS does not cut much ice.
The petitioners have demonstrated, prima facie, that several
universities and competitive examination authorities insist
upon a consolidated marksheet from a single recognised
board. The option of NIOS, therefore, cannot be treated as a
real or equivalent alternative, particularly where it compels
students to repeat multiple subjects afresh.
49. CBSE, being the principal national body entrusted with
regulating secondary and senior secondary education,
cannot absolve itself of responsibility to ensure coherence of
rules of senior secondary education with the rules the
competitive of examination in this country. Education system
in India is intertwined in such a manner that senior
secondary education is not an isolated stage but forms the
foundation upon which higher and professional education is
built. The structure of higher education admissions in the
country is intrinsically linked to the subjects studied and
examinations taken in Class XII.
50. Eligibility criteria for professional courses are framed
with reference to specific subject combinations at the senior
secondary stage. For instance, admission to medical courses
through NEET mandates the study of Physics, Chemistry, and
Biology at the Class XII level, while engineering admissions
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require Physics, Chemistry, and Mathematics.
51. These requirements presuppose that such subjects have
been pursued as part of an integrated academic curriculum
under a recognised Board. In this context, directing the
students who have already passed Class XII under CBSE to
seek recourse through NIOS disrupts the continuity of their
academic record and undermines the coherence of the
education system itself. In such a case the student would have
to undergo the examination of all 5 subjects, which can never
be a viable option.”
19. Applying the aforesaid principles to the facts of the present case, it is
evident that students presently pursuing B.A., B.Sc. (in any discipline), or
M.A. Clinical Psychology or have completed M.A. (Clinical Psychology)
Course in 2026, had embarked upon their respective courses under a
legitimate and well-founded expectation that they would be eligible to
progress to the M.Phil. in Clinical Psychology and, thereafter, obtain
registration with the RCI in accordance with the prevailing regime.
20. The abrupt introduction of the new regime, without any workable
transitional mechanism, has the effect of completely foreclosing this
established route. The consequence is that the students are effectively
required to retrace their academic steps by re-enrolling in undergraduate and
postgraduate programmes in Clinical Psychology, thereby losing years of
academic effort and financial investment. Such a requirement is manifestly
unreasonable and disproportionate. The denial of access to the M.Phil.
programme under these circumstances amounts to a retrospective withdrawal
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of a valuable right , which had already accrued to the students by virtue of
their enrolment under the earlier regime.
21. In these circumstances, the application of the new regime to the present
cohort of students would be arbitrary, inequitable, and violative of the
principles of fairness that govern administrative action.
22. For the said reasons, the new regime will not be applicable to the
students presently enrolled in B.A, B.Sc and M.A. (Clinical Psychology)
programme or completed M.A. (Clinical Psychology) in 2026 but will be
applicable to the Class XII students.
23. The aforesaid findings were already made by this Court in W.P.(C)
2399/2026 vide judgment/Order dated 05.05.2026, however, despite such
judgment/Order being passed, respondent Nos. 1 and 2 have taken no steps to
re-commence M. Phil Programme in Clinical Psychology.
24. Constrained by such inaction, petitioners have approached this Court.
Accordingly, in view of the above, respondent Nos. 1 and 2 are directed as
under:-
a) Respondent Nos. 1 and 2 are directed to issue an appropriate
clarification/ public notice within a period of 4 weeks clarifying that
the applicability of the new regime shall not extend to students covered
under earlier regime, in terms of the judgment/Order dated 05.05.2026
passed in WP(C) 2399/2026, namely, students presently pursuing
B.A./B.Sc. (any stream) and M.A. (Psychology) under the UGC
framework.
b) Respondent Nos. 1 and 2 are further directed to take steps to
recognise/recommence/continue M.Phil (Psychology) Programme for
students pursuing B.A./B.Sc. (any stream/discipline) and M.A.
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(Clinical Psychology) under UGC framework, starting from August,
2026 (Academic Session 2026-2027) and ensure continuity of such
course for such period it serves to such students.
c) Respondent Nos. 1 and 2 shall notify the concerned
universities/institutions to re-commence/continue the M.Phil
(Psychology) Programme within time-bound manner, so that the said
course shall commence starting their Academic Session 2026-2027.
25. With these directions, the petition stands disposed of.




JASMEET SINGH, J
JULY 6, 2026 / (MS)

(corrected and released on 14.07.2026)

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