Equitable considerations cannot override mandatory statutory requirements and academic regulations in university examination procedures.

The petitioner, an Assistant Grade-III employee in the Office of the District Education Officer, Gwalior, was admitted to a Ph.D. program in Sociology at Maharani Laxmi Bai Government College of Excellence

After failing her first attempt at the Ph.D. Course Work Examination, she failed to appear in the 2023 examination, citing a lack of information

She approached the High Court seeking a mandamus to allow her to participate in the forthcoming 2024 examination as her second and final attempt under the University Ordinance

The University contested the petition, stating that the petitioner had failed to submit the mandatory examination form and fees within the stipulated time, and thus no admit card could be generated

1. Whether the petitioner has an absolute right under Ordinance No. 11 to appear for the Ph.D. Course Work Examination without complying with mandatory procedural requirements such as submission of forms and fees

2. Whether a writ of mandamus can be issued to relax academic regulations on the grounds of personal hardship or sympathy

The court primarily applied the principles governing the issuance of a writ of mandamus under Article 226 of the Constitution of India, which requires the existence of a clear legal right in favor of the petitioner and a corresponding legal duty upon the respondents

Ordinance No. 11 of the University, which regulates Ph.D. course work and examinations

The doctrine that academic standards and statutory requirements must be applied uniformly and cannot be overridden by equitable or sympathetic considerations in the absence of enabling provisions

The Court reasoned that interference in academic matters is limited to cases of arbitrariness or violation of statutory provisions

It found that the petitioner failed to provide contemporaneous evidence to prove she was prevented from filing her examination form due to technical errors or lack of information

The Court rejected the argument that Ordinance No. 11 grants an "absolute right" to two attempts, clarifying that such opportunities are strictly subject to procedural compliance (forms and fees)

The Court noted that the petitioner could not claim parity with the order in Smt. Manju Soni Vs. State of M.P. (W.P. No.16782/2026) because that order had been set aside by a Division Bench in Writ Appeal No.1996/2026

The Court held that the petitioner’s status as a woman from an OBC category did not exempt her from uniform academic regulations

The Court held that sympathy and personal hardships cannot override mandatory academic requirements or statutory procedures

The writ petition was dismissed as being devoid of merit