Courts will not interfere under Article 226 where administrative decision-making is lawful and free from perversity.

The petitioners, third-year General Surgery students, challenged notices and orders issued by the respondent authorities debarring them from appearing in their final-term examinations and preventing them from filling in their examination forms.

The action arose after an incident on the campus in which Rajat Ali allegedly drove a car rashly and negligently, causing injuries to certain students. The petitioners’ names were included as accused in the resulting FIR.

They contended that they had no criminal antecedents, were not involved in any illegal activity, and had been falsely implicated. Photographs were relied upon to show that one petitioner was absent from the incident and another was attempting to pacify the situation.

They further alleged that the impugned orders were unsupported by reasons and had been passed without a proper opportunity of hearing, thereby jeopardising their careers.

The petitioners relied on Sumit Mandoliya v. State of West Bengal & Others, WPA No. 12425/2025, decided on 5 June 2025, and Sudeepto Das v. South Asia University, W.P.(C) No. 17766/2025, decided on 17 February 2026.

They also requested that the petition be treated as a mercy petition in view of their future prospects.

Whether the respondent authorities’ orders debarring the petitioners from appearing in the final-term examinations were liable to be quashed for want of reasons, violation of natural justice, or improper decision-making under Article 226 of the Constitution?

Whether the High Court should interfere with the administrative decision merely because the petitioners were named in an FIR and asserted that they had been falsely implicated?

Whether the relief sought could be granted by treating the writ petition as a mercy petition in view of the petitioners’ academic future?

The Court applied the principles governing judicial review under Article 226 of the Constitution of India, particularly that judicial review is directed primarily against the decision-making process, and not against the merits of the administrative decision itself.

Relying on Ranjit Thakur v. Union of India, 1987 (4) SCC 611, the Court held that interference is warranted only where the decision-making process is legally defective, arbitrary, biased, perverse, or otherwise improper.

The Court also considered the decisions cited by the petitioners, namely Sumit Mandoliya and Sudeepto Das, but treated them as having persuasive value and applicable only in their respective factual contexts.

The Court noted that the petitioners were named in the FIR and that further criminal proceedings, including filing of the charge-sheet and trial, would proceed in accordance with law.

It examined the impugned orders and the material on record but found no defect in the authorities’ decision-making process.

The Court held that the petitioners had not demonstrated bias, mala fides, prejudice, perversity, or any violation of the prescribed procedure.

Their reliance on photographs and their assertion of false implication did not justify judicial interference at this stage, particularly when the criminal allegations remained subject to further investigation and trial.

The Court additionally observed that, as third-year General Surgery students, the petitioners were expected to maintain a higher degree of discipline and dignity.

The cited judgments did not compel a different result because they were fact-specific and only persuasive.

It therefore declined to interfere under Article 226 and dismissed the writ petition.

No relief permitting the petitioners to fill in examination forms or appear in the final-term examinations was granted.