Mandamus to University to Forward Permanent Affiliation Proposals and Update Samarth Portal for Academic Sessions

The petitioner, Secretary of Pandit Devraj College, filed a writ petition seeking a direction to Jai Prakash University to forward a proposal to the State Government for permanent affiliation from the 2026-2030 session

Despite a Statutory Committee’s inspection and recommendation for permanent affiliation (evidenced by Letter Nos. 5220(R) and 5221(R) dated 05.05.2026), the University failed to forward the necessary documents to the State

Consequently, the petitioner’s institution could not take admissions or have its name uploaded on the Samarth Portal for the new academic session

1. Whether the respondent University should be directed to forward the recommendation for permanent affiliation to the State Government to enable a final decision under the Bihar Universities Act

2. Whether the petitioner is entitled to have the institution's name uploaded on the Samarth Portal for student admissions

Section 21(2)(d) of the Bihar Universities Act, which governs the procedure for the grant of affiliation to colleges

The principle of administrative accountability, holding that statutory bodies must perform their duties—specifically the forwarding of recommendations after inspection—within a reasonable timeframe to prevent prejudice to educational institutions

The Court observed that the University’s Statutory Committee had already inspected and recommended the college for affiliation as per the letters dated 05.05.2026

The Court found that the delay in forwarding these recommendations was the sole "inaction" of the University, which effectively paralyzed the State Government’s ability to take a final decision and hindered the college's admission process

By applying Section 21(2)(d), the Court reasoned that once the internal recommendation process was complete, the University had an obligation to transmit the records to the State

Therefore, keeping the matter pending in court was unnecessary, and a time-bound administrative direction was required to rectify the procedural bottleneck

Upon receipt, the Director, Department of Higher Education (Respondent No. 4), must pass an appropriate order regarding permanent affiliation and the uploading of the college's name on the Samarth Portal within a further period of two weeks, provided there are no other legal impediments