Odisha High CourtAdministrative and Public LawEducation Law

Parity permits a late NOC renewal application where admission deadlines are extended.

JANAKALYAN COLLEGE OF NURSING, RAMACHANDRAPUR, KENDRAPARAv.STATE OF ODISHA

Parity permits a late NOC renewal application where admission deadlines are extended.. JANAKALYAN COLLEGE OF NURSING, RAMACHANDRAPUR, KENDRAPARA vs STATE OF ODISHA. Odisha High Court. LawLens
The LawLens card for this judgmentXLinkedInWhatsApp

In brief

The question

1. Whether the petitioner could receive relief on parity with institutions granted an opportunity to apply for NOC renewal under the earlier order, notwithstanding that order’s description as a one-time, non-precedential measure.

The court held

The Court allowed the petitioner a final opportunity to apply for NOC renewal, through the e-Portal or physically, by 17 October 2026, subject to payment of ₹60,000 over and above the prescribed fees.

It also directed

It directed that failure to meet the deadline would not be followed by any further extension.

Upon receipt of the application, the authorities were to consider it in accordance with law as soon as possible, preferably by 27 October 2026.

The writ petition was disposed of accordingly.

01Facts

The petitioner, a B.Sc. Nursing institution, had received renewal of its No Objection Certificate (NOC) in previous academic years but did not apply for renewal for the current year within the prescribed time.

¶ 3–4 · pp. 2–4

In an earlier batch of petitions, the High Court had permitted similarly situated institutions to apply by 24 August 2026, subject to payment of an additional ₹50,000, while describing that relief as a one-time measure with no precedential value.

¶ 3–4 · pp. 2–4

The admission deadline was subsequently extended from 30 September to 31 October 2026.

¶ 5–7 · pp. 4–5

Relying on that extension and the earlier order, the petitioner sought a similar opportunity to apply for renewal.

¶ 5–7 · pp. 4–5

02Issues

i.1. Whether the petitioner could receive relief on parity with institutions granted an opportunity to apply for NOC renewal under the earlier order, notwithstanding that order’s description as a one-time, non-precedential measure.

¶ 6–8 · pp. 4–6

ii.2. Whether, in light of the extended B.Sc. Nursing admission deadline, the petitioner could be permitted to apply for renewal subject to a new deadline and additional payment.

¶ 7–9 · pp. 5–6

03Law Applied

The Court exercised its jurisdiction under Articles 226 and 227 of the Constitution.

p. 1

It applied the principle of parity, reasoning that an order in a similar matter should not be disregarded solely because it was stated to have no precedential value.

¶ 7 · p. 5

It relied on State of Odisha v. Priyambada Pattanaik, SLP No. 10598 of 2024, decided on 9 September 2024, where the Supreme Court applied the terms of an earlier order to cases involving the same set of facts and circumstances in the same State, despite that order’s non-precedential character.

¶ 7 · p. 5

The Court also considered its order of 13 August 2026 in W.P.(C) No. 7990 of 2026 and batch, which had granted a one-time opportunity to similarly situated institutions, subject to conditions.

¶ 4, 8–9 · pp. 3–6

04Reasoning

Although the petitioner had not applied within the earlier deadline and had not demonstrated a diligent attempt to do so, the Court considered the subsequent extension of the admission deadline to 31 October 2026 a material change in circumstances.

¶ 7–8 · pp. 5–6

Given that change and the relief granted to similarly situated institutions, the Court found no reason to deny the petitioner the same benefit on parity.

¶ 7–8 · pp. 5–6

To account for the petitioner’s delay and the limited time remaining, it imposed a stricter deadline and a higher additional payment than those required under the earlier order.

¶ 9 · p. 6

05Holding

The Court allowed the petitioner a final opportunity to apply for NOC renewal, through the e-Portal or physically, by 17 October 2026, subject to payment of ₹60,000 over and above the prescribed fees.

¶ 9–10 · pp. 6–7

It directed that failure to meet the deadline would not be followed by any further extension.

¶ 9–10 · pp. 6–7

Upon receipt of the application, the authorities were to consider it in accordance with law as soon as possible, preferably by 27 October 2026.

¶ 9–10 · pp. 6–7

The writ petition was disposed of accordingly.

¶ 9–10 · pp. 6–7
Odisha High Court

Original Court PDF

JANAKALYAN COLLEGE OF NURSING, RAMACHANDRAPUR, KENDRAPARAvsSTATE OF ODISHA

Odisha High Court · October 16, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment