Delhi High CourtEducation LawAdministrative and Public Law

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

Man Mental Health Awareness And Networking Society, Through Its Authorised Signatoryv.Rehabilitation Council Of India, Ministry Of Social Justice A Empowermentnd & Ors.

New Education Policy transition cannot retrospectively withdraw vested academic rights of students enrolled under earlier regimes.. Man Mental Health Awareness And Networking Society, Through Its Authorised Signatory vs Rehabilitation Council Of India, Ministry Of Social Justice A Empowermentnd & Ors.. Delhi High Court. LawLens
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In brief

The question

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

The court held

The Court held that the new RCI/UGC regime shall not apply to students currently enrolled in B.A., B.Sc. (any discipline), or M.A. (Clinical Psychology) programmes

It also directed

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

01Facts

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

pp. 2-3

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

¶ 4

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)

¶ 5

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

¶ 10

02Issues

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

p. 6/14

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

p. 15/17

03Law Applied

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

¶ 1

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

¶ 19

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

¶ 21

Provisions in the judgment · 1 · Linked ones open on LawLens

University Grants Commission Act, 1956 Section 26

04Reasoning

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

¶ 20

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

¶ 20

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

¶ 21

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

¶ 21-22

05Holding

The Court held that the new RCI/UGC regime shall not apply to students currently enrolled in B.A., B.Sc. (any discipline), or M.A. (Clinical Psychology) programmes

¶ 23

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

¶ 25
Delhi High Court

Original Court PDF

Man Mental Health Awareness And Networking Society, Through Its Authorised SignatoryvsRehabilitation Council Of India, Ministry Of Social Justice A Empowermentnd & Ors.

Delhi High Court · May 05, 2026

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