University cannot withhold results after permitting academic progression and examinations without timely objection to eligibility.

The petitioner, an LL.B. student, filed a writ petition under Article 226 of the Constitution seeking a mandamus to allow her to fill examination forms and appear for the 8th and 10th-semester examinations in June 2025.

On 05.06.2025, the Court granted interim relief permitting the petitioner to appear for the 10th-semester examination, provided the results were withheld pending court leave.

The petitioner argued that the University had permitted her to attend classes and take previous semester exams without objection, leading to a bona fide progression in her studies.

The respondents contended that the petitioner was ineligible for higher semesters due to non-fulfillment of academic conditions prescribed by the University Ordinance and Promotion Rules.

1. Whether the respondents, having permitted the petitioner to progress through the course and appear in previous examinations without objection, are estopped from withholding results due to alleged non-fulfillment of eligibility criteria.

2. Whether the doctrine of legitimate expectation and the prevention of manifest injustice justify the court's intervention in academic progression disputes.

The court primarily exercised its discretionary jurisdiction under Article 226 of the Constitution of India to prevent manifest injustice.

It relied on the doctrine of Legitimate Expectation, which arises when a consistent course of conduct by an authority leads a party to reasonably believe their actions are in accordance with the rules.

The court applied the principle that a student should not be penalized for the administrative lapses or failures of an institution to enforce its own regulations at the appropriate stage, provided the student acted bona fide.

The Court observed that the petitioner’s progression was not a "one-time instance" but a continuous permission granted by the respondents over a considerable period, which created a legitimate expectation that her progression was lawful.

The Court found that the respondents failed to enforce the applicable Ordinance and Promotion Rules at the relevant stages.

Consequently, the Court determined that after the petitioner had already appeared in the 10th-semester examination under an interim order, withholding her result would result in "manifest injustice" and "serious prejudice" to her career.

It was reasoned that since no fault was attributable to the petitioner, she should not suffer for the University's failures.

The holding was qualified: the declaration of results remains subject to the petitioner fulfilling any academic requirements or passing marks as per the rules.

Notably, the Court clarified that this order was passed in the "peculiar facts and circumstances" of the case and shall not be treated as a legal precedent.

No order as to costs was made.