### Termination of Ph.D. Programme Without Formal Show-Cause Notice and Inquiry Violates Principles of Natural Justice

The petitioner was admitted to the Ph.D. (M.E.) program at the respondent University on May 5, 2022.

On May 15, 2025, the Assistant Registrar issued an order terminating the petitioner’s Ph.D. program under Point 14(b)(iv) of the Ph.D. Manual due to unauthorized absence for a major part of the semester.

A subsequent corrigendum dated May 23, 2025, added allegations of unsatisfactory academic performance.

The respondent claimed the decision was based on a Discipline Post Graduate Committee (DPGC) evaluation and a report from the petitioner's Guide.

The petitioner challenged these orders on the grounds of violation of the principles of natural justice.

The respondents raised a preliminary objection regarding the availability of an alternative remedy of appeal under Point 14(c) of the Manual.

1. Whether the termination of the Ph.D. program was legally sustainable in the absence of a formal show-cause notice and opportunity of hearing.

2. Whether the availability of an alternative remedy of appeal bars the writ petition when principles of natural justice are allegedly violated.

The Court applied the Principles of Natural Justice, specifically audi alteram partem (the right to be heard), as a prerequisite for administrative actions entailing civil consequences.

It interpreted Point 14 of the Ph.D. Manual, which prescribes conditions for termination due to inadequate academic performance or indiscipline, noting that "deficient" students are entitled to warnings or reviews before termination.

The court held that where a fact-finding inquiry is essential to resolve disputed allegations, an appeal cannot be considered an "effective remedy" if the initial decision-making process was void of procedural fairness.

The Court found that while the respondents claimed to have sent an email on July 29, 2024, seeking an explanation, that email failed to indicate any intention to terminate the Ph.D. program and thus did not constitute a valid show-cause notice.

The Court reasoned that terminating a student's Ph.D. involves disputed questions of fact regarding attendance and academic progress; therefore, a formal notice and an opportunity to lead evidence are mandatory before invoking Point 14 of the Manual.

The Court rejected the respondent's argument regarding the alternative remedy, stating that since no proper fact-finding inquiry was conducted initially, the right to appeal under Point 14(c) was not an adequate substitute for the lack of original due process.

The Court held that simply directing a student to appear before a committee without disclosing the intent to terminate the program does not satisfy the requirements of natural justice.

The respondents were granted liberty to initiate fresh action against the petitioner strictly in accordance with the law and by following proper procedural safeguards.