Promotion to subsequent academic year cannot be granted without attending classes or fulfilling attendance requirements.

The Appellant, a student of Bachelor of Occupational Therapy at Respondent No. 2 (affiliated with Respondent No. 1), failed two subjects and had a shortage of attendance in a third subject during her Second Year exams in July/August 2024

Although initially promoted to the Third Year per a headnote in the results, she failed to clear one backlog subject in the March 2025 supplementary exam, leading to her debarment from the Third Year

Following interim orders from a Single Judge, she was eventually permitted to take Third Year exams and a further supplementary exam for the Second Year backlog

While she cleared the Second Year backlog in February 2026, her subsequent Third Year results (declared March 2026) showed she had failed two subjects

The Appellant sought promotion to the Fourth Year, claiming she met the criteria of passing three theory subjects and all practicals

The Single Judge dismissed her writ petition, observing she had not attended any Fourth Year classes

1. Whether a student can be promoted to the Fourth Academic Year of a course without having attended any classes for that year due to pending backlogs from previous years.

2. Whether the Appellant’s fulfillment of the "three theory subjects and all practicals" criteria entitles her to promotion despite the timeline of her results and lack of attendance.

The court primarily applied the promotion criteria of the University of Delhi, which requires a candidate to pass at least three theory subjects and all practicals for promotion to the Fourth Year; however, this is subject to the mandatory requirement of academic residency and attendance.

The court relied on the precedent established in Aman Bansal v. University of Delhi & Anr. (Neutral Citation 2006:DHC:4398-DB), which held that a candidate who has not attended a single class cannot seek admission or promotion to the subsequent academic year.

The Court reasoned that the Appellant's eligibility for promotion was hindered by the retrospective timeline of her academic clearances. Although she eventually cleared her Second Year backlog, she did so only in February 2026, meaning her Third Year results could not be legally declared until March 2026.

By this time, the Fourth Year classes, which commenced in October 2025, were nearly complete.

The Court noted that even if the Appellant met the "three theory subjects" criteria, she had failed two other subjects in the Third Year and had not attended any instruction for the Fourth Year.

Applying the Aman Bansal principle, the Court found that academic promotion cannot be granted in a vacuum of attendance, regardless of the reasons (including delayed court-ordered exams) for the delay in result declaration.

The Court directed that the Appellant must clear her Third Year backlogs in the upcoming June 2026 examinations before seeking further promotion.

The Letters Patent Appeal and associated applications were dismissed with no order as to costs.