New Education Policy transition cannot retrospectively withdraw vested academic rights of students enrolled under earlier regimes.

The Petitioner, a society providing mental health training, challenged the sudden discontinuation of the M.Phil in Clinical Psychology and the restructuring of psychology education following the National Education Policy (NEP) 2020

Under the new regime notified by the UGC and RCI, the M.Phil programme was prohibited

new academic pathways (4-year B.A./B.Sc. and 2-year M.A. Clinical Psychology) were established for professional registration in the Central Rehabilitation Register (CRR)

This change rendered students currently enrolled in traditional 3-year B.A./B.Sc. or M.A. Psychology programmes ineligible for the professional pathway unless they repeated undergraduate or postgraduate years to satisfy the new criteria

1. Whether the abrupt implementation of the new educational framework without a transitional policy for existing students is arbitrary and discriminatory

2. Whether students currently pursuing degrees under the previous regime have a "vested right" or "legitimate expectation" to complete their professional qualification pathway

The Court primarily applied Article 226 of the Constitution of India regarding the judicial review of administrative actions

principle of "Legitimate Expectation" and protection against the "retrospective withdrawal of a valuable vested right," as articulated in Prabhroop Kaur Kapoor v. Union of India

standard of "reasonableness and proportionality" in administrative policy-making to ensure that education shifts do not cause irreversible prejudice to existing cohorts

The Court observed that while the State has the authority to reform education policy via NEP 2020, the lack of a transitional mechanism created a legal vacuum for current students

The Court reasoned that students who enrolled in B.A., B.Sc., or M.A. programmes under the old regime did so with the expectation that they could progress to an M.Phil and RCI registration

Forcing these students to retrace their academic steps (potentially losing several years and financial resources) was deemed "manifestly unreasonable and disproportionate"

The Court found that applying the new regime to the current cohort amounted to an arbitrary retrospective withdrawal of rights, violating principles of fairness

The Court issued a mandamus protecting the existing cohort from being barred by the new eligibility criteria, thereby allowing them to complete their qualifications under the previous pathway