Madras High Court

Head of Department appointments must follow the principle of seniority on a three-year rotational basis.

E.Chandra vs The Registrar

Madras High CourtJUDGMENT: July 07, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellants, three senior Professors at Bharathiar University, had served as Heads of Department (HoD) for approximately ten years

Source reference: para. 9

In October 2025, the University issued proceedings appointing other Professors as the new HoDs, effectively replacing the appellants

Source reference: paras. 2-4

The appellants challenged these appointments via writ petitions, which were dismissed by the writ court on November 11, 2025

Source reference: para. 1, 12

The appellants then filed these writ appeals, contending that as the senior-most Professors, they were entitled to continue in their positions

Source reference: para. 9
02

Issues

1. Whether the appointment of a Head of Department under the Bharathiar University Act is a permanent tenure for the senior-most Professor or subject to a three-year rotational term

Source reference: paras. 6, 11

2. Whether University Grants Commission (UGC) regulations regarding the rotation of HoD positions prevail over state university practices

Source reference: para. 15
03

Law Applied

Section 45 of the Bharathiar University Act, 1981, which stipulates that the term for an HoD is three years, with eligibility for reappointment

Source reference: para. 5-6

Ordinance 2001 of the University and Ordinance 4(IV) of the University Grants Commission, the latter of which explicitly mandates that where multiple Professors exist in a department, the Vice-Chancellor shall appoint the HoD by observing the principle of rotation based on seniority for a three-year term

Source reference: paras. 7, 10

The principle of federal supremacy, noting that the University Grants Commission Act, 1956, as an Act of Parliament, prevails over conflicting State Acts or practices

Source reference: para. 15
04

Reasoning

The Court reasoned that a conjoint reading of the University Act and the UGC Ordinances necessitates a rotational system

Source reference: para. 11

While the appellants argued that their seniority granted them a right to remain HoD, the Court clarified that "seniority" must be read alongside the "principle of rotation"

Source reference: para. 11

The Court found that the objective of this scheme is to ensure equal opportunity among all senior Professors and prevent the monopolization of administrative roles, which ultimately benefits students through diverse academic leadership

Source reference: para. 14

Since the appellants had already served nearly ten years—well beyond the statutory three-year term—the University was justified in rotating the position to the next senior-most Professor in line with the UGC mandate

Source reference: paras. 9, 13, 16
05

Holding

The tenure for the post of Head of Department is strictly three years and must be filled on a rotational basis among eligible senior Professors

The Court dismissed the writ appeals and confirmed the orders of the writ court

Source reference: para. 17

The University’s decision to appoint new HoDs was upheld as being in accordance with both the Bharathiar University Act and the prevailing UGC Regulations

Source reference: para. 16
Madras High Court

Original Court PDF

E.ChandravsThe Registrar

Madras High Court · July 07, 2026

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