Ankita Jagannath Sonawale vs Maharashtra National Law University Thr Its Registrar And Ors

2026:BHC-AUG:24514-DB
( 1 ) RA (CIVIL) 95 OF 2026
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
BENCH AT AURANGABAD
REVIEW APPLICATION (CIVIL) NO. 95 OF 2026
IN WP/4881/2026
Ankita Jagannath Sonawale
Age : 23 years, Occ. Student,
R/o. A/p. Pimpari, Tq. Koregaon,
Dist. Satara. ….APPLICANT

VERSUS
1. Maharashtra National Law University,
Chh. Sambhajinagar, Through its Registrar,
Maharashtra National Law University,
Chh. Sambhajinagar.
2. The Vice Chancellor,
Maharashtra National Law University,
Chh. Sambhajinagar.
3. CPGLS Convenor,
Maharashtra National Law University,
Chh. Sambhajinagar.
4. Grievance Redressal Committee,
Maharashtra National Law University,
Chh. Sambhajinagar. ….RESPONDENTS
...
Ms. Ankita Jagannath Sonawale, Party In Person
Mr. S. K. Kadam, Advocate for Respondents in W.P.
…
CORAM
: SMT. VIBHA KANKANWADI AND
AJIT B. KADETHANKAR, JJ.
DATE
: 18.06.2026

( 2 ) RA (CIVIL) 95 OF 2026
JUDGMENT :- (Per Ajit B. Kadethankar, J.)
. The applicant (Party-in-Person) has filed this Civil Application for
review of the judgment and order dated 30.04.2026 passed by this Court in
Writ Petition No.4881 of 2026.
2. The applicant, a student pursuing post graduation studies in the
Faculty of Law was disallowed by the respondent – Maharashtra National Law
University, Chhatrapati Sambhajinagar (“The University” for brevity) from
participating in the second/last semester examination of the course for not
complying with the requirement of minimum 75% attendance in accordance
with the Rules of Maharashtra National Law University Regulations 2020
(“The Rules of 2020” for brevity).
3. The applicant assailed the prohibition imposed by the University
vide Writ Petition No.4881 of 2026 before this Court. After hearing the parties
at length, this Court, vide its judgment and order dated 30.04.2026 dismissed
the writ petition. Feeling dissatisfied by rejection of her Writ Petition, the
applicant has filed this civil application for review.
4. At the outset it needs to be recorded that the Writ Petition was
filed for immediate relief in the month of April 2026 for seeking permission to

( 3 ) RA (CIVIL) 95 OF 2026
participate in the semester examination. The Writ Petition is dismissed with a
reasoned order. The examination is already over. Now the applicant, by taking
recourse to review u/o XLVII of the Civil Procedure Code 1908, seeks to re-
open the matter and for direction to the University to conduct a special
examination for her.
5. The applicant has come up with following prayers in this review
application :
“a) Review, recall, modify, and/or reconsider the judgment and
order passed by this Hon'ble Court in Writ Petition No. 4881 of
2026 in the interest of justice, equity, and fair play;
b) Quash and set aside the decision dated 28.04.2026-passed by
Respondent No.3 Grievance Redressal Committee rejecting the
grievance raised by the Applicant;
c) Hold and declare that the proceedings conducted by
Respondent No.4 Grievance Redressal Committee were arbitrary,
mechanical, non-speaking in nature, and violative of the
principles of natural justice;
d) Exercise judicial review over the procedure adopted by
Respondent No.4 -Grievance Redressal Committee and examine
whether the said committee was constituted and conducted
proceedings in accordance with the applicable UGC Regulations
and prescribed institutional procedure;
e) Direct the Respondents to place on record the CCTV footage of
the meeting/proceedings of the Grievance Redressal Committee
held on 27.04.2026, in respect whereof the Applicant had
already submitted RTI Application dated 08.05.2026 within the
period during which CCTV footage is preserved by the
University;

( 4 ) RA (CIVIL) 95 OF 2026
f) Direct the Respondents to place on record the original
attendance sheet circulated to students through e-mail on
23.04.2026 together with the corresponding institutional
attendance records, lecture-wise attendance registers, guest
lecture attendance records, and all related documents relied
upon for determination of attendance percentages;
g) Direct the Respondents to place on record the complete
month-wise, lecture-wise, and subject-wise attendance details of
Mr. Viraj Gapat together with the attendance registers
maintained by the concerned faculty members and the records
pertaining to additional attendance allegedly granted on account
of guest lectures;
h) Direct production of the attendance and service records
pertaining to the place of employment of Mr. Viraj Gapat during
the relevant period for the limited purpose of comparison and
verification with the lecture attendance records maintained by
the Respondent University;
i) Hold and declare that the selective and non-transparent grant
of attendance additions and discretionary relaxation by the
Respondents is arbitrary, discriminatory, biased, and violative of
Article 14 of the Constitution of India;
j) Hold and declare that if attendance records or institutional
documents originally circulated to students were subsequently
altered, reconstructed, inconsistently presented, or
misrepresented before this Hon'ble Court for securing a
favourable judicial determination, the same constitutes serious
interference with judicial proceedings and warrants appropriate
action in accordance with law relating to abuse of process and
contempt of court;
k) Permit the Applicant to place on record additional medical
papers, treatment documents, WhatsApp awareness group
screenshots, and all other supporting material demonstrating the
bona fide medical circumstances and family healthcare
background of the Applicant;
l) Direct the Respondents to ensure that the Applicant's
dissertation process, dissertation evaluation, viva voce, and all
related academic formalities are conducted fairly, objectively,

( 5 ) RA (CIVIL) 95 OF 2026
transparently, and strictly in accordance with law without any
bias, coercion, prejudice, retaliation, discrimination, or mental
harassment to the Applicant;
m) Direct the Respondents to conduct a Special Examination/Re-
Examination for the Applicant in respect of the concerned
Semester-II examinations within a time period deemed fit by this
Hon'ble Court and permit the Applicant to complete the LL.M.
programme subject to fulfillment of all other academic
requirements;
n) Pass any other further orders, directions, or reliefs which this
Hon'ble Court may deem fit and proper in the facts and
circumstances of the present case.”
6. The applicant has formulated following grounds to seek review of
the judgment and order (supra) :
A. Error apparent in respect of attendance computation:
B. Arbitrary, unreasoned, and procedurally improper decision of
respondent Nos.3 and 4 :
C. Deliberate suppression, reconstruction, and presentation of
incorrect attendance records before this Hon’ble Court
amounting to interference with judicial proceedings and
contempt of Court :
D. Arbitrary and discriminatory grant of extra attendance to
selected students :
E. Non-consideration of genuine medical circumstances, family
healthcare background, and subsequent supporting medical
material :
F. Non-consideration of the principle of reasonable relaxation and
subsequent stay operating prospectively :
G. Grossly arbitrary, biased, and discriminatory grant of
attendance benefits to favoured students while denying similar
equitable consideration to the applicant :

( 6 ) RA (CIVIL) 95 OF 2026
H. Non-consideration of the doctrine of proportionality in
administrative action resulting in disproportionate academic
prejudice to the applicant :
7. We have heard the party-in-person at length and also offered a
hearing to learned advocate Mr. S. K. Kadam representing the respondent –
University.
8. Applicant’s arguments :-
(a) The applicant, to make out a case at ground “A” i.e. “error
apparent on the face of the record” submitted that the UGC
Guidelines do not provide for any percentage relaxation. The
applicant vehemently argued that the submission made by learned
advocate for the University was not supported by any statute,
ordinance, regulation, etc., whereby if a student attained at least
67% attendance, the Vice-Chancellor could offer some addition
thereto for touching the requirement of 75% attendance. The
applicant, therefore, submitted that it is an error apparent on the
face of the record.
(b) Moving to Grounds “B and C”, the applicant submitted that as
per the final attendance sheet circulated by the respondent –

( 7 ) RA (CIVIL) 95 OF 2026
University on 23.04.2026, her attendance was at least a bit more
than what was submitted by learned advocate for the respondent –
University before this court. She would submit that as per the data
submitted by learned advocate for the respondent – University in
the writ petition, her attendance was shown as 61 (45.86%) against
133 lectures. It is her contention that as per the final attendance
sheet dated 23.04.2026, her attendance was in fact 65 (48.87%)
against 133 lectures. The applicant submits that learned advocate
for the respondent – University did not produce the original
attendance record before this Court and instead submitted that, on
instructions from the University, he had made such an erroneous
statement.
(c) Referring to Ground ‘D’, the applicant argued that she learnt
through oral information from some staff member of the University
that additional attendance had been granted to certain students by
the University. Upon going through the final attendance sheet dated
23.04.2026, the applicant could not find any details making
provision for additional attendance credit. The applicant ought to
have been given similar treatment by the University by granting her
additional attendance credit. Thus, as per the applicant due to

( 8 ) RA (CIVIL) 95 OF 2026
arbitrary and discriminatory treatment by the University the
applicant suffered loss of her examination.
(d) On Ground ‘E’, the applicant submits that since the applicant
and her family believed in Ayurveda, she did not undergo any
Allopathic or orthopedic treatment. It is her allegation that the
University insisted only upon a certificate issued by M.B.B.S./M.D.
medical practitioners, whereas the applicant has case papers to
show that she had undergoing Ayurvedic treatment with the
assistance of her sister, who herself is a B.A.M.S. practitioner. The
applicant submitted that admittedly she could not file such medical
papers before the Grievance Redressal Committee or before this
Court; however, in this review application she wants to produce the
same on record to make out her case. It is her submission that this
Court ought to have relied upon the medical certificate which she
had produced along with the writ petition.
(e) Ground ‘F’ concerns non-consideration of “the principle of
reasonable relaxation and subsequent stay operating prospectively”.
The applicant submits that relaxation in attendance deficiency and
interim protection to students in attendance matters are permissible
in appropriate circumstances. She would submit that although the

( 9 ) RA (CIVIL) 95 OF 2026
judgment delivered by the Delhi High Court in the case of In Re :
Sushant Rohilla, has been stayed by the Honorable Supreme Court
vide order dated 26.05.2026, the stay would be operative
prospectively.
(f) Ground ‘G’ in the application refers to the applicant’s batch-
mate, to whom the University allegedly gave different, yet favorable
treatment. Referring to the name of the said student, the applicant
submits that while he was in full-time employment as a Law Clerk
of this Court at Aurangabad, the University still accommodated him
by showing the requisite attendance. The applicant’s contention is
that a person working as a Law Clerk in the High Court could not
have achieved the requisite attendance by attending the course
during its ordinary timing of 9.00 a.m. to 12.00 noon. The applicant
alleged a biased approach on the part of the respondent –
University and some faculty members in extending discriminatory
treatment to her.
(g) The last Ground ‘H’ in the review application pertains to the
doctrine of proportionality and disproportionate academic
prejudice. Applicant reiterates the said principle on the same facts
which she has argued in the Writ Petition.

( 10 ) RA (CIVIL) 95 OF 2026
9. We have given thorough opportunity of hearing to the applicant.
The original copy of the Ayurvedic treatment documents is produced on
record. The same is marked as Annexure “X” for identification.
10. Respondents’ arguments:
(a) Mr. S. K. Kadam, learned advocate for the respondent –
th
University placed on record the Minutes of the 28 P.G. Academic
and Examination Committee Meeting dated 10.10.2023 conducted
under the Chairmanship of the Chairperson of the P.G. Academic
and Examination Committee of Maharashtra National Law
University, Aurangabad, Centre for Post Graduate Legal Studies.
(b) Mr. Kadam denies that he made any incorrect statement
before this Court. He submitted that the decision requiring at least
67% attendance and permitting further addition to meet the
minimum requirement of 75% attendance was taken in the meeting
of the Committee, while also recording the reasons for granting
such relaxation in attendance. The Minutes of the Meeting are taken
on record and marked as “X-1” for identification.
(c) He further submits that the Center for Post Graduate Legal
Studies is established in the University as per the UGC Guidelines

( 11 ) RA (CIVIL) 95 OF 2026
communicated to all HEIs vide D.O. No.5-1/99(CPP-II) dated 18
January 2013. The CPGLS has adopted a policy prescribing a
minimum of 67% attendance for students who wish to avail medical
leave. The said policy was adopted in its 28th P.G. Academic and
Examination Committee Meeting dated 10 October 2023 vide
Resolution No.3, which was approved by the Vice-Chancellor.
(d) It is further submitted by the respondents that it was always
the stand of the University that had the applicant attained at least
67% attendance upon production of convincing medical evidence,
she could have been elevated to the requisite attendance criteria i.e.
75%.
(e) On behalf of the respondent – University, it is submitted that
none of the official, faculty of the University has any grudge against
the applicant. The university never offers nor has ever caused any
discriminatory treatment to any student.
(f) To conclude, Mr. Kadam, learned advocate for University
argues that the decision to invoke rule No. XI (b) Of the Rules of
2020 to ban the applicant for examination was in fact a painful one,
but it was taken up extremely cautiously in view of the mandate of
the Rules. It is submitted that the examination is already over, and

( 12 ) RA (CIVIL) 95 OF 2026
there is neither any provision nor any precedent nor any extra
ordinary exceptional circumstances to conduct special examination
of the applicant.
11. Consideration :
11.1 Before proceeding, for convenience we reproduce the text of the
Order XLVII of the Code of Civil Procedure which reads thus:
ORDER XLVII
REVIEW
1. Application for review of judgment.—(1) Any person considering
himself aggrieved—
(a) by a decree or order from which an appeal is allowed, but from
which no appeal has been preferred,
(b) by a decree or order from which no appeal is allowed, or
(c) by a decision on a reference from a Court of Small Causes,
and who, from the discovery of new and important matter or
evidence which, after the exercise of due diligence was not within
his knowledge or could not be produced by him at the time when
the decree was passed or order made, or on account of some
mistake or error apparent on the face of the record or for any
other sufficient reason, desires to obtain a review of the decree
passed or order made against him, may apply for a review of
judgment to the Court which passed the decree or made the order.

( 13 ) RA (CIVIL) 95 OF 2026
(2) A party who is not appealing from a decree or order may apply
for a review of judgment notwithstanding the pendency of an
appeal by some other party except where the ground of such appeal
is common to the applicant and the appellant, or when, being
respondent, he can present to the Appellate Court the case on which
he applied for the review.
[Explanation.—The fact that the decision on a question of law on
which the judgment of the Court is based has been reversed or
modified by the subsequent decision of a superior Court in any
other case, shall not be a ground for the review of such judgment.]
11.2 The main issue is of whether the applicant touched at least 75%
attendance mandated by the 2020 Rules or at least 67% with a convincing
case for grant of additional attendance. We tested applicant’s case on the facts
and record placed by her before us. Thereafter, upon dissatisfying with the
applicant’s case, we dismissed the Writ Petition on merits.
11.3 In the light of the parameters for review set out in Order XLVII of
the Code of Civil Procedure, we now test applicant’s case in the light of her
each objection.
(a) At Ground ‘A’ of the Petition, the applicant submits that there
is error apparent as regards to the rule of mandatory attendance,
the minimum attendance and scope for addition. Applicant’s main

( 14 ) RA (CIVIL) 95 OF 2026
thrust is on the statements made on behalf of the respondent –
University in the Writ Petition. We find that the requirement of 75%
attendance is provided in the 2020 Rules itself. The Rules are
binding on the University. The provision for relaxation of the gap
between 75% and 67% is neither un-reasoned, arbitrary nor
erroneous. In fact, the same is well supported by the Resolution of
the P. G. Academic and Examination Committee. As such, Ground A
seeking review, as mentioned in the application, does not meet the
requirements for review as contemplated under Order XLVII of the
Code of Civil Procedure. It cannot be overlooked that it is not the
case of the applicant that she had at least 67% attendance. In view
of this, we find that no case is made out for recording any error of
fact apparent on the face of the record. Applicant’s concept about
‘error apparent on the face of record’ is misconceived one.
(b) Grounds B and C refer to a final attendance sheet dated
23.04.2026 on which the applicant has heavily placed reliance.
However, the applicant has not produced a copy of such attendance
sheet. Instead, the applicant seeks a direction in the review
application against the University to produce such sheet. The
applicant, on the one hand, asserts and relies upon the existence of

( 15 ) RA (CIVIL) 95 OF 2026
a particular document and counters the University for submitting
contrary data. On the other hand, the applicant does not place such
document on record and shoulders the responsibility of producing
the same upon the University. She submits that the University has
already served her the final attendance sheet, however, she could
not print it out. This is unacceptable. We record here that there is
not a single whisper in the Writ Petition about any such Final
Attendance Sheet dated 23.04.2026. As per her own version, the
applicant was well aware about such final attendance sheet dated
23.04.2026 even before she was summoned before the Grievance
Redressal Committee. Now the applicant wants to rely upon that,
and she seeks directions to the University to produce the said
document. We reject such contention and argument at threshold.
(c) There is one more finding which we wish to record here. As
per the applicant’s contention, the data provided by the University
before us in the writ petition reflected her attendance as 45.86%.
The applicant, by referring to the final attendance sheet, submits
that her attendance was in fact 48.87%. It is her further submission
that by adding three additional attendance credits, her attendance
could reach 51.12%. Thus, it is clear that in any case, the applicant

( 16 ) RA (CIVIL) 95 OF 2026
could neither reach 75% attendance nor 67% attendance. Hence,
Grounds B and C do not make out a case for review.
(d) The applicant herself states that she didn’t attend the
Grievance Redressal Committee meeting. However, in the review
application, she challenges composition of the committee and the
procedure of the meeting. The applicant even sought information
under the Right to Information Act from the University on this
count. Applicant has further prayed for directions to the University
for procuring CCTV footage of the meeting proceedings. The
applicant alleges that the decision of the Committee is arbitrary, un-
reasoned and procedurally improper. She also alleged deliberate
suppression, reconstruction and presentation of incorrect
documentation before this Court amounting to interference with the
judicial proceedings.
The applicant fails to attend the meeting, doesn’t place on
record the document on which she seeks review – while the
document is already served to her, the reason for not tendering the
said copy before this court is non-convincing. The reliance placed by
the learned advocate for the respondent – University is a matter of
record, and more particularly the rules and the record of the

( 17 ) RA (CIVIL) 95 OF 2026
institution. We are constrained to observe that the contents in the
review application are absolutely reckless and irresponsible.
(e) Grounds ‘D’ and ‘G’ refer to the applicant’s allegations against
the University for extending favorable treatment to certain other
students. In Ground D, the applicant relies upon hearsay
information allegedly received from a staff member regarding
enhancement of attendance of some students. In Ground G, the
applicant attempts to bring into question the attendance record of
her batch-mate by referring to his engagement as a Law Clerk in
this Court. We deprecate such practice to be placed in service while
a review application is filed and argued. We have no doubt in our
mind that these are absolutely reckless and irresponsible
contentions raised in the review application. In no way these
grounds help the applicant in seeking review of the judgment and
order passed by this Court in Writ Petition No.4881 of 2026.
(f) So far as Ground “E” is concerned, the applicant cannot fill up
lacunae in her case vide a review application by producing such
documents and by adding such facts which were not disclosed by
her while arguing the Writ Petition.

( 18 ) RA (CIVIL) 95 OF 2026
We find that all the contentions pleaded and argued by the
applicant in support of this ground are irrelevant. This time some
new story is raised by the applicant about her unwellness and
treatment. There is absolute no reference to such documents,
incidences and treatments in the Writ Petition, while it was well
within knowledge of the applicant while arguing the Writ Petition.
We have held in the writ petition that the applicant cannot take
benefit of her own wrong. We repeat the said principle while
answering this ground.
(g) Grounds “F” and “H” are drafted and argued in an entirely
irrelevant manner. It is clear that the applicant did not attend the
semester lectures as required for mandatory attendance under the
2020 Rules. The University is undoubtedly bound by these Rules. It
is also true that the applicant could not meet even the attendance
percentage required for seeking relaxation, namely 67% attendance.
The applicant could not dispute this fact. On the contrary, she
submitted that her attendance could, at best, have been 51.12%. In
these circumstances, we find that Grounds “F” and “H”, as argued
and explained by the applicant, do not make out a case for review
under Order XLVII of the Code of Civil Procedure.

( 19 ) RA (CIVIL) 95 OF 2026
(h) Considering that the interim order dated 26.05.2026 passed
in Special Leave to Appeal (Crl) No.9450 of 2026 (Challenge to
Delhi High Court’s judgment in Sushil Rohilla case) is passed after
disposal of the Writ Petition No.4881 of 2026 on 30.04.2026,
applicant’s argument ‘to review our judgment in the light of the
interim order dated 26.05.2026 (supra)’, is found to be a misplaced
one.
11.4 We must record here that the review application is drafted and
argued as if its an appeal against the judgment and order passed by this Court
in Writ Petition No.4881 of 2026. Each of the objection raised by the applicant
is already argued by the applicant at length in the Writ Petition. The objections
are dealt on their own merits as per the record available. Now, the applicant
again agitates the same issues.
11.5 We find that the applicant failed to make out a case for review.
Although the applicant articulates her draft with a legal proposition that an
appeal must not be placed under the disguise of a review, the applicant
practically has sought to re-appreciate her case as if this Court is sitting in an
appeal over its own judgment and order. It is a matter of fact that the
examination was already over in the month of May itself. The applicant has

( 20 ) RA (CIVIL) 95 OF 2026
sought a direction to the respondent – University to re-conduct the said
examination for her. We do not accept such prayer, as it is beyond the scope of
review powers.
11.6 We are well guided by the principles of law laid down by the
Hon’ble Supreme Court in its two landmark judgments on the scope of review
application under Order XLVII of the Civil Procedure Code. We gainfully place
our hands on law laid down by the Hon’ble Supreme Court in Lily Thomas
and Others Versus Union of India and Others reported in (2000) 6 SCC 224
and Government of NCT of Delhi and Another vs. K. L. Rathi Steels Limited
and Others reported in (2024) 7 SCC 315 which lays down that neither an
appeal under the disguise of review should be entertained, nor subsequent
development in law or the subject-matter shall give a reason for review.
11.7 We are not only disappointed due to audacity in the approach of
the applicant, but rather we are worried. The applicant is a law graduate, who
is now prosecuting the Post Graduation studies at Maharashtra National Law
University Aurangabad and soon shall be entering into the noble profession of
legal field. We notice that to overcome her own defaults the applicant
adopted such extreme measures, which not only makes her case an abuse of
process, but we are afraid, that it would hamper her own career too.

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11.8 We quote at least three instances where the applicant has taken
impermissible liberty.
(A) In the Writ Petition, the petitioner at no point of time
said that she didn’t attend the Grievance committee meeting.
In the present review application, the applicant, however,
states on oath that ‘for unavoidable circumstances’ she didn’t
attend the meeting. Then she raises wild allegations against
the University and the Grievance Committee. Further, the
applicant even prays to call for CCTV footage of the
committee hearing proceedings.
(B) The additional medical documents on which the
applicant now relies, are coming from own custody. In the
Writ Petition, the petitioner nowhere whispered about such
treatment or documents. After noticing the findings of this
court in the judgment in Writ Petition, the petitioner raised
this new case.
(C) The applicant very irresponsibly and recklessly named
her batch-mate to demonstrate that the University
discriminated herself. Without looking to own default, the

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applicant then has made wild allegations against everybody
including her batch-mate, the Faculties, the University, the
Grievance Committee etc., except herself.
We are cautious to refrain ourselves from commenting
and recording further. But we record our serious displeasure
and disappointment on the applicant’s conduct.
11.9 The applicant is yet to enter into practice. She is at tender age of
learning the practice and procedure of advocacy. At such stage of professional
career, if appearance before the Courts of Law is meant and taken up in any
undisciplined scurrilous way and without clean hands, then we are seriously
concerned about the professional career of the new entrants in this noble field.
This is high time that we must deprecate such practice.
11.10 On facts, we have held that the applicant could not make out a
case u/o XLVII of the Civil Procedure Code 1908. A cause taken up before the
Courts of Law must be bonafide. Of course, every proceeding before a court is
to seek justice; but the concept of ‘justice’ doesn’t mean ‘whatever I want and
howsoever I put it’.

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11.11 We are seriously tempted to impose heavy costs for the reasons
recorded above. However, considering that the applicant is a student we hold
on our hands.
11.12 Before parting, we deem it appropriate to direct the registry to
mask the name of applicant’s batch-mate pleaded in the review application, to
secure his privacy and to avoid future unpleasant consequences.
12. For the reasons recorded above, we find that no case is made out
for interference. Hence, we pass following order :
O R D E R
i. The Civil Application for review stands dismissed.
ii. Registry is directed to mask the name of applicant’s batch-mate
which is pleaded in the review application at paragraph Nos.1 to 19
from Ground G and at such places where it appears.
( AJIT B. KADETHANKAR, J. ) ( SMT. VIBHA KANKANWADI, J. )
PRW