A university cannot withhold a bona fide student’s degree for its own clerical error.

The appellant was admitted to the University’s five-year BA.LLB programme for the 2016–2021 session.

She received marksheets for semesters 1–6, but the University withheld her marksheets for semesters 7–10, her degree, and other documents because her name did not appear in the admission disclosure list sent to the Himachal Pradesh Private Educational Institutions Regulatory Commission (HP-PERC).

The University and the Document Verification Committee acknowledged that the appellant’s name appeared in the University’s Green Sheet/student registration records, but that, due to a clerical error, another student’s name had been sent to HP-PERC in her place.

The University also referred to discrepancies between the Green Sheet and gazette records for earlier semesters.

The High Court dismissed the appellant’s writ petition, leaving her to approach a competent court; she appealed.

1. Whether the appellant was entitled to the withheld marksheets, degree, and other documents despite her name being omitted from the admission disclosure list due to the University’s clerical error.

2. Whether discrepancies in records relating to earlier semesters, or the availability of a competent court, justified withholding the documents or refusing relief in the writ proceedings.

The Court applied the principle that a bona fide student should not suffer the consequences of an institution’s own clerical error where the institution’s records establish the student’s admission and successful completion of examinations.

Where the material facts establish entitlement and no factual dispute survives, relegating the student to a competent court is not warranted.

No statute or binding precedent was identified as the basis of the Court’s decision.

Pratima Das v. State of Himachal Pradesh & Ors., 2026 INSC 13, was cited by the appellant in support of her case.

The University admitted that the appellant was admitted against an allotted seat, that her name appeared in its primary internal record, and that she had cleared all ten semesters.

It attributed her omission from the disclosure list to its previous administration’s clerical error, while the Committee’s account was consistent with that explanation.

The Court held that the appellant could not be made to bear the consequences of that error.

The discrepancies concerned earlier semesters for which marksheets had already been issued; neither respondent alleged that she had failed, and the University affirmed that she had passed all examinations.

Accordingly, those discrepancies did not affect the relief sought, and no unresolved factual dispute justified requiring her to pursue a separate proceeding.

It directed the University to issue her marksheets for semesters 7–10, her degree, and other relevant documents, including her Character Certificate and Migration Certificate, within four weeks of receiving the judgment.

No order as to costs was made.