Universities must process affiliation applications despite pending property-title disputes.

PERI College, which already offered B.Pharm courses, applied to the University to introduce M.Pharm courses in Pharmaceutical Analysis and Pharmaceutics for the 2026–27 academic year.

The college’s property had been sold in enforcement proceedings under the SARFAESI Act, 2002; the sale was challenged before the DRT in S.A. No. 493 of 2025, where an interim order was in force.

The college had paid ₹8.28 crore pursuant to a conditional order of the DRT.

The University did not process the application, and the Single Judge directed it to do so for provisional affiliation, subject to the college meeting the University’s statutory conditions.

The University appealed, arguing that its regulations required clear title to the property.

Whether the University was required to process and decide the college’s application for new courses despite the pending dispute over title to the property.

Whether the Single Judge’s direction to process the application warranted interference in appeal.

The Court noted that the property dispute arose from proceedings under the SARFAESI Act, 2002 and was pending before the DRT; it did not decide the merits of that dispute.

The University’s regulations and statute governed the consideration of the application, including the appellant’s asserted requirement of clear title.

The Court held that the University must process and decide the application under its rules, rather than refuse consideration before assessing the application on its merits.

The Court treated the Single Judge’s order as requiring consideration of the application under the University’s rules, not as granting recognition or affiliation outright.

Given that the college was already conducting courses, had applied to introduce new courses, and the University had conducted an inspection, the University was required to make a decision on the application.

The pending title dispute before the DRT did not justify declining to consider the application in advance; the University’s decision remained subject to its governing rules, and the Court expressed no view on the merits.

The University was to do so without being influenced by the observations in the writ court’s orders.

The appeal was disposed of without costs, and the connected miscellaneous petitions were closed.