Administrative authorities must provide an opportunity to cure deficiencies before rejecting institutional course approval applications.

The Petitioner institution applied to the Rehabilitation Council of India (RCI) for approval to conduct two-year B.Ed. Special Education courses in Learning Disability (LD) and Intellectual Disability (ID) for the 2024-25 academic session

Initially, RCI returned the applications based on circulars dated 04.01.2024 and 08.03.2024, which discontinued new approvals for two-year programs in favor of Integrated Teacher Education Programmes under the National Education Policy 2020

These circulars were quashed by a Coordinate Bench of the Delhi High Court in a previous writ petition (W.P.(C) 5679/2024), which directed RCI to process the applications according to law

Subsequently, RCI issued an impugned order dated 24.06.2024, rejecting the proposals citing three deficiencies: (i) the submitted PwD certificate was valid only until 2023; (ii) the student list lacked disability and UDID details; and (iii) faculty details and consents were missing

The Petitioner challenged this rejection, asserting the deficiencies were factually incorrect and that they were denied an opportunity to cure them

Whether the RCI's rejection of the Petitioner’s proposal without providing an opportunity to justify or cure alleged deficiencies violated the principles of natural justice.

Whether the RCI could sustain its rejection based on a policy of discontinuing two-year courses that had already been quashed by the Court in previous litigation.

The court primarily applied the doctrine of Audi Alteram Partem (principles of natural justice), relying on Maneka Gandhi v. Union of India, which established that administrative actions entailing civil consequences must involve a fair hearing even in the absence of express statutory provisions

It further applied the principle from Mohinder Singh Gill v. Chief Election Commissioner, which dictates that the validity of an order must be judged by the reasons mentioned therein and cannot be supplemented by fresh grounds in an affidavit

The court also followed Madhu Vachaspati Institute of Pharmacy v. Pharmacy Council of India, affirming the regulatory duty to communicate specific deficiencies and allow institutions a reasonable opportunity to rectify them before final rejection

The Court found the RCI’s grounds for rejection to be factually untenable and procedurally flawed. Regarding the PwD certificate, the Petitioner held a valid certificate at the time of application which was subsequently revalidated until 2026

The student list actually contained the UDID numbers and disability details allegedly missing

Concerning faculty details, the Petitioner had provided a list, and the Court noted that RCI’s manual did not explicitly require "consents" at that stage

The Court emphasized that fairness in administrative action requires prior disclosure of defects and a meaningful opportunity to cure them; by notifying deficiencies and rejecting the proposal simultaneously, RCI acted arbitrarily

Furthermore, the Court rejected RCI’s attempt to revive the discontinued policy via an additional affidavit, noting that the previous judgment quashing the discontinuation of two-year courses for the 2024-25 session was binding and could not be circumvented by referring to earlier circulars

It held that RCI cannot reject proposals based on curable deficiencies without affording the institution an opportunity to respond

The Court directed RCI to: (i) carry out an inspection of the Petitioner’s institution within four weeks; (ii) notify the Petitioner of any defects found and grant two weeks to cure them; and (iii) pass a final speaking order within one week thereafter