Discontinuation of M.Phil (Clinical Psychology) cannot apply retrospectively to students already enrolled in qualifying undergraduate or postgraduate courses.

The Petitioners are students who completed a B.A. in non-psychology disciplines followed by an M.A. in Clinical Psychology

Under the National Education Policy (NEP) 2020, the University Grants Commission (UGC) issued Ph.D. Regulations 2022, specifically Regulation 14, which prohibited higher educational institutions from offering M.Phil. programmes

A subsequent UGC notice dated 30.01.2024 discontinued the M.Phil. (Clinical Psychology) programme from the 2025-26 academic session

This abrupt change rendered students in the Petitioners' position "pathless," as they were now ineligible for registration with the Rehabilitation Council of India (RCI) unless they retraced their academic steps by completing a fresh four-year undergraduate degree in Psychology

The Petitioners sought a writ to facilitate their admission to M.Phil. and protect their academic pathway

1. Whether the discontinuation of the M.Phil. (Clinical Psychology) programme without a transitional mechanism for students already enrolled in the old academic regime is arbitrary and unconstitutional

2. Whether the new regulatory framework can be applied retrospectively to students who pursued their degrees under the legitimate expectation of the previous eligibility criteria

The Court applied Article 226 of the Constitution of India regarding the judicial review of administrative actions

It relied on the principle of Legitimate Expectation, asserting that students who acted upon prevailing policies have a vested interest that cannot be abruptly withdrawn to their detriment

The Court integrated the doctrine of Proportionality and Reasonableness, holding that administrative actions must not cause "serious and irreversible prejudice"

It specifically followed the precedent set in Prabhroop Kaur Kapoor v. Union of India, W.P.(C) 15086/2025, which established that while courts refrain from interfering in education policy, they must intervene when such policies are applied arbitrarily or retrospectively to withdraw accrued rights

The Court observed that under the old regime, a "7-year pathway" (3 years B.A./B.Sc. + 2 years M.A. + 2 years M.Phil.) allowed for RCI registration, whereas the new regime forced a "9 to 11+ year pathway" by requiring students to repeat undergraduate studies

The Court reasoned that these students embarked on their education with a "legitimate and well-founded expectation" of eligibility

The Court held that the sudden removal of the M.Phil. route without a "workable transitional mechanism" was "manifestly unreasonable and disproportionate"

It characterized the requirement for students to retrace years of academic and financial investment as an "arbitrary and inequitable" retrospective withdrawal of a valuable right

Consequently, the Court determined that the new regime must only apply to new entrants (Class XII students) and not to the "protected cohort" already in the system

The Court directed: (a) Respondent Nos. 1 and 2 to issue a public notice within four weeks clarifying the exemption for this cohort; (b) the recognition and recommencement of the M.Phil. (Clinical Psychology) programme for these students starting from the 2026-2027 academic session; and (c) notification to all universities to continue the M.Phil. course for as long as it serves the protected students