Adverse orders passed on grounds not specified in the show-cause notice violate principles of natural justice.

The Petitioner, a recognized institute by the All India Council of Technical Education (AICTE), received an extension of approval for its Hotel Management program for the Academic Year (AY) 2018-19

On 07.06.2018, Respondent No. 2 (Gujarat Technological University) issued a show-cause notice (SCN) alleging staff and infrastructure deficiencies

The Petitioner replied on 20.06.2018

However, on 21.06.2018, Respondent No. 2 passed the impugned order placing the Petitioner in a "No Admission Zone" for AY 2018-19, citing entirely new grounds—such as charging excess fees and retaining original certificates—which were not part of the original SCN

The High Court granted interim relief on 17.07.2018, staying the order

This stay was upheld by a Division Bench in Letters Patent Appeal No. 1009 of 2018

By the time of the final hearing in 2026, the students admitted under the interim order had already completed their courses

1. Whether the impugned order dated 21.06.2018 was arbitrary and violative of the principles of natural justice by relying on grounds not mentioned in the show-cause notice

2. Whether the University could restrain admissions after AICTE had granted approval and beyond the schedule prescribed by the Supreme Court

3. Whether the challenge survived given that the students admitted via interim relief had already graduated

Principles of Natural Justice, specifically the requirement that an adverse order cannot be based on grounds absent from the show-cause notice

The supremacy of AICTE approval over state/university restrictions as established in State of T.N. v. Adhiyaman Educational & Research Institute (1995) 4 SCC 104

The mandatory admission schedule fixed by the Supreme Court in Parshvanath Charitable Trust v. AICTE (2013) 3 SCC 385, which prohibits authorities from considering deficiencies for a current academic year after the April 10th deadline

Section 29 of the Gujarat Technological University Act, 2007 regarding affiliation powers

The Court observed that the impugned order was procedurally flawed because Respondent No. 2 introduced "absolute new grounds" in the final order that were never put to the Petitioner in the SCN, thereby denying them a fair opportunity to respond

On the merits of the AICTE approval, the Court noted that once AICTE granted an extension on 04.04.2018, the University could not unilaterally block admissions for the same year based on subsequent inspections, especially after the April 10th cutoff established in Parshvanath Charitable Trust

Finally, the Court found that because the Petitioner had operated under a stay for eight years, allowing students to graduate without any complaints from the students or the Fee Regulatory Committee during the pendency of the petition, the impugned order had become "infructuous" for all practical purposes

The interim relief was made absolute, regularizing the admissions of the students who had already passed out; the Court imposed a token cost of ₹25,000 to be deposited with the High Court Legal Services Committee within four weeks