Students with zero attendance cannot claim promotion to subsequent semesters despite illegal withholding of previous results.

The Appellant, an LL.B. student at the University of Delhi, was detained in Semester-II due to a 27.58% attendance record.

Though provisionally allowed to sit for Semester-II exams, his results were withheld, leading to a denial of admission into Semester-III.

Consequently, the Appellant did not attend any Semester-III classes or appear for its exams.

He subsequently took re-admission in Semester-II in January 2026 to avoid a gap.

The Single Judge directed the declaration of results but refused promotion to Semester-IV, noting that the Appellant had "nil attendance" for Semester-III.

1. Whether a student who has neither attended any classes nor appeared for examinations in a particular semester can claim the right to progress to the subsequent semester.

2. Whether the benefit of the precedent in Courts on its Own Motion Re: Suicide Committed by Sushant Rohilla regarding attendance shortages can be extended to cases of "nil attendance".

The Court applied the attendance requirements governed by the Bar Council of India (BCI) norms and the University Prospectus, which requires cumulative passing of papers for promotion.

It relied on the principle established in Harsh Meena & Ors. v. University of Delhi & Ors. [LPA 740/2025], which holds that permitting students who have not attended even a single class to sit for exams would discourage sincere students and reward indiscipline.

It distinguished the "shortage of attendance" principles in Courts on its Own Motion Re: Suicide Committed by Sushant Rohilla [W.P.(CRL) 793/2017] from cases of total absence.

The Court reasoned that academic continuity cannot be restored by skipping an entire semester of schooling.

It noted that while the Appellant’s Semester-II result was withheld, he remained inactive during the Semester-III period and only approached the Court once Semester-IV was already underway.

The Court emphasized a fundamental distinction between a "shortage of attendance" (where a student participates but falls below the threshold) and "nil attendance" (where the student is entirely absent from the academic process).

The Court held that allowing a student to bypass a semester without attending a single class—regardless of whether the initial denial of admission was attributable to them—would undermine academic integrity and public perception of legal education.

The Court dismissed the appeal and upheld the Single Judge's order. No order as to costs was made.

The Court concluded that the ratio of Sushant Rohilla is confined to attendance shortages and cannot be used to bridge a total academic vacuum.