Patna High Court
Administrative and Public LawCivil Procedure and Evidence

University and college granted final two-week opportunity to comply with directions concerning publication of withheld B.Ed. results.

Chandan Kumar vs The State of Bihar

Patna High CourtJUDGMENT: July 28, 20263 MIN READSOURCE JUDGMENT
University and college granted final two-week opportunity to comply with directions concerning publication of withheld B.Ed. results.. Chandan Kumar vs The State of Bihar. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, Chandan Kumar, a student of Chanakya Foundation (B.Ed. College), approached the Patna High Court alleging that his final B.Ed. result had not been published and that the concerned University and college had not issued the requisite marksheet and certificate.

Source reference: p. 3, para. 2

The matter was previously considered on 2 February 2026, when the Court directed the respondent University and college to examine the grievance, file a counter affidavit, and issue the certificate if there was no legal or administrative impediment.

Source reference: p. 3, para. 2

The Court was informed that an identical grievance raised by Moni Kumari in CWJC No. 13246 of 2025 had been resolved: after receiving a communication from the college, Aryabhat Knowledge University updated her marksheet and provisional certificate on its website portal on 19 November 2025 and informed the college and students.

Source reference: p. 2, paras. 2–4

However, despite the earlier order in Chandan Kumar’s case, no corresponding action had been taken and no counter affidavit had been filed on behalf of the concerned respondents.

Source reference: p. 3, paras. 3–4
02

Issues

1. Whether the respondent University and college had complied with the Court’s direction dated 2 February 2026 to examine and redress the petitioner’s grievance concerning publication of his B.Ed. result and issuance of the marksheet/certificate.

Source reference: p. 3, paras. 2–4

2. Whether, in view of the continued non-compliance and failure to file a counter affidavit, further time should be granted to the concerned respondents, subject to the possibility of appropriate action against the defaulting authorities.

Source reference: p. 4, para. 5

3. Whether the grievance in Moni Kumari’s connected writ petition had been redressed, thereby warranting disposal of that petition.

Source reference: p. 2, paras. 2–5
03

Law Applied

The Court applied the principles governing writ jurisdiction and compliance with judicial directions, particularly that parties and public authorities must comply with orders issued by the High Court and place their position before the Court through an appropriate counter affidavit.

Source reference: p. 2, paras. 2–5; p. 4, para. 5

Where the underlying grievance is remedied, a writ petition may be disposed of as infructuous or as having been satisfied. Conversely, continued non-compliance with a judicial order may justify the Court in granting limited further time and warning that appropriate action may be taken against the responsible authorities.

Source reference: p. 2, paras. 2–5; p. 4, para. 5
04

Reasoning

In Moni Kumari’s case, the University admitted that, following the college’s communication, her marksheet and provisional certificate had been uploaded on the University’s portal and the relevant parties had been informed. Since the petitioner accepted that her grievance had consequently been resolved, the Court treated the relief as having been granted and disposed of the petition.

Source reference: p. 2, paras. 2–5

In Chandan Kumar’s case, however, the analogous relief remained outstanding. Although the Court had issued directions on 2 February 2026, the respondents had neither filed a counter affidavit nor demonstrated compliance, particularly when the University had already remedied the substantially identical grievance of another student.

Source reference: p. 3, paras. 2–4

The Court therefore granted a final period of two weeks to respondents 5 to 8 to comply, while expressly reserving the possibility of action against the authorities found responsible for the default.

Source reference: p. 4, para. 5
05

Holding

CWJC No. 13246 of 2025, filed by Moni Kumari, was disposed of because her marksheet and provisional certificate had been uploaded and her grievance stood redressed.

In CWJC No. 678 of 2026, filed by Chandan Kumar, the Court did not finally dispose of the matter. As a last indulgence, respondents 5 to 8 were granted two weeks to comply with the order dated 2 February 2026 and address the petitioner’s grievance; failing compliance, the Court warned that appropriate orders would be passed against the erring authorities. The matter was directed to be listed on 11 August 2026.

Source reference: p. 4, paras. 5–6
Patna High Court

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Chandan KumarvsThe State of Bihar

Patna High Court · July 28, 2026

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