Eligibility for admission must be subsisting on the date of application, not the notification date.

The Petitioner qualified for the UGC-NET (June-2024) with a result declared on October 17, 2024

Per the Certificate of Eligibility issued by the National Testing Agency (NTA), the validity for Ph.D. admission was one year from the result date, expiring on October 16, 2025

On October 16, 2025, Jamia Millia Islamia (Respondent No. 2) issued a notification for Ph.D. admissions for the 2025-26 session

However, the online application portal opened only on October 20, 2025, and remained open until November 8, 2025

The Petitioner submitted his application under the "Exempted Category" (exempt from entrance tests due to UGC-NET qualification) on October 27, 2025

Although provisionally selected and successful in the interview held on December 19, 2025, the Petitioner was ultimately denied admission on the grounds that his UGC-NET scorecard had expired by the time he applied

The Petitioner challenged this denial, seeking a Mandamus to treat the date of the admission notification as the relevant date for determining certificate validity

1. Whether the validity of a UGC-NET certificate for Ph.D. admission should be determined by the date of the admission notification or the date of the actual submission of the application form

2. Whether the Petitioner was entitled to admission under the "Exempted Category" despite his eligibility certificate having expired prior to the date of application

The court applied the eligibility criteria stipulated in the Respondent University’s Revised Ph.D. Ordinance – 9 (IX), which grants entrance test exemptions to candidates qualifying in national-level tests like UGC-NET

The court further relied on the specific terms of the NTA Certificate of Eligibility, which limits the validity of the scorecard for Ph.D. admission to exactly one year from the date of result declaration

The court also considered the principle established in Asha v. Pt. B.D. Sharma University of Health Sciences (2012) 7 SCC 389, which permits judicial intervention in cut-off dates only where the candidate is meritorious and not at fault

The court found that the Petitioner’s UGC-NET certificate was valid strictly from October 17, 2024, to October 16, 2025

While the admission notification was released on the final day of the certificate's validity (October 16, 2025), the university’s application window did not commence until October 20, 2025

The Petitioner filed his application on October 27, 2025, by which time his Certificate of Eligibility had already lapsed

The court reasoned that to qualify for the "Exempted Category," a candidate must possess a valid scorecard on the actual date of application

The court distinguished the precedent in Asha (supra), noting that in that case, the candidate was fully qualified on the relevant date but denied admission due to external errors; conversely, the Petitioner here was fundamentally unqualified on the date of application due to the term expiry of his certificate

The court emphasized that it cannot use Article 226 to extend sacrosanct admission deadlines or validity periods defined by examining bodies like the NTA

The court affirmed that the one-year validity period for the UGC-NET certificate is absolute and had expired on October 16, 2025, whereas the application was filed on October 27, 2025

Consequently, the university’s decision to deny admission was upheld as legally sound