A meritorious minor cannot be denied admission for administrative errors in school-recognition records.

The minor petitioner, Rahul Kumar, through his widowed mother and natural guardian, challenged the order dated 1 July 2026 by which the Principal of PM-SHRI Jawahar Navodaya Vidyalaya, Piprakothi, rejected his candidature/admission to Class VI on the ground that his previous school was allegedly unrecognized.

The State authorities clarified that the petitioner’s previous school had been granted provisional recognition under Section 18 of the Right of Children to Free and Compulsory Education Act, 2009, read with Rule 11 of the Bihar Right to Education Rules, 2011, for Classes I to VIII, by certificate dated 10 June 2022.

The recognition was valid from 18 December 2021 to 18 December 2024, covering the period during which the petitioner studied in Classes III and IV.

After expiry, the school applied for renewal, and no order cancelling or withdrawing its recognition under Section 18(3) of the RTE Act had been passed.

The school’s status had been incorrectly shown as “unrecognized” on the UDISE portal due to a technical/data discrepancy, which was subsequently rectified; the updated records reflected the school as recognized for Classes I to VIII.

The petitioner had qualified for Class VI admission under the OBC Rural quota, securing 96.25 marks and overall rank 72.

The Navodaya Vidyalaya Samiti stated that all 80 seats had already been filled and no vacancy remained.

Whether the petitioner’s admission to Jawahar Navodaya Vidyalaya could be rejected solely on the basis of an erroneous UDISE portal entry showing his previous school as unrecognized, when the school had possessed valid recognition during the relevant period?

Whether the petitioner, having qualified on merit and being blameless for the administrative discrepancy, was entitled to appropriate remedial accommodation despite all regular Class VI seats having been filled?

Whether the competent authorities could lawfully create a supernumerary seat to protect the petitioner’s academic interest without disturbing admissions already made?

The Court applied Section 18 of the Right of Children to Free and Compulsory Education Act, 2009, which regulates recognition of schools, and Rule 11 of the Bihar Right to Education Rules, 2011, under which the petitioner’s previous school had received provisional recognition for Classes I to VIII.

The Court further relied on the principle that a minor child should not suffer adverse academic consequences because of an administrative or technical error attributable to governmental authorities, particularly where the child has acted in accordance with the applicable process and has qualified on merit.

It also applied a balancing principle: the integrity of the regular admission process and admissions already made should be preserved, while a lawful remedial mechanism may be devised to protect the innocent petitioner’s legitimate academic interest.

The Court found that the school was recognized during the material period when the petitioner studied there, and that no competent authority had cancelled or withdrawn such recognition.

The erroneous UDISE entry was therefore treated as an administrative/data discrepancy rather than proof that the school was unrecognized.

Since the petitioner had no control over recognition, renewal, or governmental portal entries, he could not fairly be penalized for the error.

His eligibility was reinforced by his independent performance in the entrance examination, where he obtained 96.25 marks and rank 72.

Although the Samiti had acted with reference to the portal status and all regular seats had been filled, the Court held that these considerations could not justify making the minor bear the consequences of an official lapse.

It consequently directed the competent authorities to devise a lawful solution, including, if necessary and subject to approval under the applicable rules, creation of a supernumerary seat.

The Court held that the petitioner could not be denied admission on the basis of the erroneous “unrecognized” status reflected on the UDISE portal, particularly when his previous school had valid recognition during the relevant period and the petitioner had qualified on merit.

The Secretary, Ministry of Education, Navodaya Vidyalaya Samiti, CBSE, and other concerned authorities were directed to deliberate and formulate a viable and lawful arrangement for the petitioner’s admission.

If required and permissible under the applicable rules, a supernumerary Class VI seat was to be created for him.

The exercise was to be completed within two weeks, and the judgment was directed to be immediately communicated to the concerned authorities for compliance.