Exclusion of B.Pharm graduates from MBA eligibility was upheld as a rational university policy decision.

The petitioner, a Bachelor of Pharmacy (B.Pharm) graduate, challenged the DAVV Information Brochure for the academic year 2025–26, which excluded B.Pharm graduates from eligibility for admission to the MBA (Public Health) and MBA (Hospital Administration) programmes.

He contended that B.Pharm graduates had previously been eligible and that their exclusion was arbitrary, discriminatory, and unsupported by academic reasons.

The petitioner relied on eligibility criteria followed by other institutions and on Chithra N. v. All India Institute of Medical Sciences, 2022 SCC OnLine Del 2076.

The University defended the exclusion as a policy decision based on its survey, placement data, industry feedback, and its assessment that B.Pharm graduates were less suited to the managerial and healthcare-administration competencies required for the courses.

It also submitted that the admissions process for the relevant academic year had already been completed, rendering the petition infructuous.

Whether the University’s decision to exclude B.Pharm graduates from eligibility for the MBA (Public Health) and MBA (Hospital Administration) programmes was arbitrary, discriminatory, or violative of Article 14 of the Constitution?

Whether the High Court should interfere under Article 226 with the University’s academic and eligibility policy decision?

Whether the petition had become infructuous because the admission process for the relevant academic year had already been completed?

The Court exercised judicial review under Article 226 of the Constitution, examining whether the University’s eligibility classification was arbitrary, discriminatory, or constitutionally impermissible under Article 14.

The Court applied the principle that academic institutions possess discretion to prescribe eligibility conditions and formulate course-related policies, particularly where such decisions are based on academic, professional, placement, or institutional considerations; judicial interference is unwarranted absent arbitrariness or other constitutional infirmity.

The Court considered Chithra N. v. All India Institute of Medical Sciences, 2022 SCC OnLine Del 2076, but held that the decision was factually distinguishable and did not assist the petitioner.

It also applied the principle that relief relating to an academic admission process may be declined where the process has already been completed and the petition has consequently become infructuous.

The Court found that the exclusion of B.Pharm graduates was founded on a considered institutional policy rather than an arbitrary classification.

The University had relied on placement experience, industry feedback, and the perceived lack of competencies in areas such as clinical coordination, hospital budgeting, healthcare human-resource management, epidemiology, and healthcare quality frameworks.

The Court accepted the University’s distinction between its MBA programmes, which operated within a management and business framework, and programmes offered by other institutions that were characterised as public-health or hospital-management courses with a social-service orientation.

Since the petitioner did not specifically rebut this distinction or demonstrate that the policy lacked a rational basis, the Court declined to interfere with the University’s academic judgment under Article 226.

The reliance on Chithra N. was rejected as that case was distinguishable on its facts.

Independently, the Court held that the completed admission process rendered the petition infructuous.

The Court further held that the petition had become infructuous because the relevant admission process had already concluded.

The writ petition was accordingly dismissed, with no direction to restore B.Pharm eligibility or permit the petitioner to participate in the completed admission process.