University cannot withhold results for admissions under mandated EWS reservation increases despite the absence of formal affiliation.

The petitioners successfully cleared the B.Ed. entrance examination and were admitted to respondent No. 2 (the Institution) under the Economically Weaker Section (EWS) category for the 2019-21 academic session.

Following the 103rd Constitutional Amendment, the Ministry of Human Resource Development (MHRD) issued an Office Memorandum (O.M.) on 17.01.2019, and the NCTE issued a letter on 08.07.2019, directing institutions to increase seat capacity to accommodate EWS reservations without affecting existing quotas.

Respondent No. 1 (the University) subsequently issued a letter on 24.09.2019 to self-financed institutes to implement these directives.

Consequently, the Institution admitted 106 students, exceeding its 100-seat limit.

Upon completion of the course, the University refused to declare the petitioners' results, contending that the Institution had not obtained a formal "separate affiliation letter" for the increased intake.

1. Whether the respondent University could legally withhold the petitioners' results on the grounds that the Institution exceeded its sanctioned intake when such intake was necessitated by the 103rd Constitutional Amendment and sanctioned by the University's own directives.

The court primarily applied the 103rd Constitutional Amendment regarding EWS reservations and the MHRD Office Memorandum dated 17.01.2019.

Clause 2(c) of the O.M. stipulates that Central Educational Institutions shall increase seats over their annual permitted strength to ensure that seats for other categories remain unaffected by the EWS quota.

The court further relied on the NCTE directive dated 08.07.2019, which mandated the implementation of EWS reservation policies in teacher education institutions.

The court determined that the objective of the MHRD’s O.M. was to provide the immediate benefit of the 103rd Constitutional Amendment to eligible candidates.

It noted that the Institution acted upon the University’s own communication dated 24.09.2019, which directed the implementation of the NCTE’s EWS reservation policy.

The court rejected the University’s argument regarding the necessity of a formal affiliation letter, stating it contradicted the University's prior written permission and constituted a mere formality.

Critically, the court held that the petitioners could not be faulted for an internal administrative dispute between the University and the Institution, emphasizing that students should not suffer due to procedural technicalities after successfully completing their course.

The court held that the University’s withholding of results was unjustified as the admission was aligned with constitutional mandates and the University's own prior instructions.

All pending applications were disposed of.