Facts
The Petitioner, an LL.M. student at Agnel’s School of Law, failed two subjects in the Semester-I backlog examination conducted by Mumbai University
Source reference: para. 4The University had previously issued Circular No. 61 of 2025 (dated May 5, 2025) stipulating that revaluation applications must be submitted online within a window starting 7 days after result declaration and lasting for 12 days
Source reference: para. 6, 25The results were declared on November 18, 2025, and the revaluation link was active from December 1 to December 13, 2025
Source reference: para. 18-19During this window, 246 other students successfully applied
Source reference: para. 19The Petitioner failed to apply, claiming he was unaware of the results due to the University’s failure to publish a specific notification on its website
Source reference: para. 11-13He sought a writ of mandamus to reopen the revaluation link and allow his admission to the second year
Source reference: para. 2Issues
1. Whether the University’s failure to publish a separate notification regarding the declaration of results on its official website constituted an arbitrary lapse violating Articles 14 and 16 of the Constitution
Source reference: para. 112. Whether a student can seek the reopening of a revaluation link after the expiry of a prescribed statutory timeline communicated via a general circular
Source reference: para. 22, 27Law Applied
The court applied the principle of "constructive notice," holding that a duly published university circular serves as sufficient notice to all stakeholders
Source reference: para. 25It relied on the precedent of *Maharashtra State Board of Secondary and Higher Secondary Education v. Paritosh Bhupeshkumar Sheth (1984 4 SCC 27)*, which establishes that statutory boards have the autonomy to formulate policies on examination conduct, evaluation procedures, and the finalization of results
Source reference: para. 28The court also invoked the doctrine from *Union of India v. Mohanlal Kapoor (1974 1 SCR 797)*, asserting that the principles of natural justice (*audi alteram partem*) do not extend to the "twilight zone of mere expectation"
Source reference: para. 31Furthermore, Article 14 of the Constitution was cited to emphasize that granting exclusive relief to one negligent student would constitute unfair discrimination against those who followed the rules
Source reference: para. 32Reasoning
The Court reasoned that Circular No. 61 of 2025 provided clear, unambiguous timelines for revaluation, and since 246 other students (including one from the Petitioner's own college) successfully applied, the system was transparent and functional
Source reference: para. 19, 25, 31The Court rejected the Petitioner’s argument that results must be notified in a specific format, holding that the University as a statutory body cannot be dictated to beyond the requirements of law
Source reference: para. 27-28The Court found the Petitioner’s interpretation of the circular—claiming it applied only to specific professional courses—to be a "misreading" of the document
Source reference: para. 29Additionally, the Court noted that the Petitioner approached the Court on January 19, 2026, well after the revaluation process had concluded and the next semester had commenced; therefore, "setting the clock back" would be academically unproductive and inequitable
Source reference: para. 22, 30Holding
The Court dismissed the Writ Petition and discharged the Rule
It held that there was no infringement of fundamental rights or breach of statutory duty by the University
Source reference: para. 31-32The Court concluded that granting the Petitioner a "backdoor entry" by reopening the revaluation link solely for him would violate the mandate of Article 14, which requires equals to be treated equally
Source reference: para. 32No order was made as to costs
Source reference: para. 33Original Court PDF
Nikiteshkumar Vijaykumar Kotangale v. The Vice-Chancellor, Mumbai University & Ors. [2026:BHC-AS:9393-DB]
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