Madhya Pradesh High Court

Vice-Chancellor may exercise discretionary powers under University Ordinances to consider Ph.D. submission extensions on humanitarian grounds.

Smt. Mrinalini Dwivedi vs Vice Chancellor Jiwaji

Madhya Pradesh High CourtJUDGMENT: July 14, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a Ph.D. student of English Literature, initially enrolled in 2014 but failed to complete the course within four years. She re-registered on January 17, 2019, under Ordinance No. 11, which required completion by January 18, 2023

Source reference: para. 2

The petitioner cited the COVID-19 pandemic and two pregnancies (childbirths in August 2020 and March 2023) as reasons for her inability to submit her thesis on time

Source reference: para. 3

Consequently, the University issued an order on November 20, 2024, declining her permission to proceed further

Source reference: para. 3

The petitioner approached the High Court seeking a direction to the University to extend the submission period and accept her research work

Source reference: para. 1
02

Issues

1. Whether the Vice-Chancellor can exercise discretionary powers under the applicable University Ordinances to grant an extension for Ph.D. thesis submission on humanitarian or extraordinary grounds

Source reference: para. 6

2. Whether the petitioner is entitled to parity with the precedent set in Kirti Soni vs. Jiwaji University, Gwalior (W.P. No. 13923/2024) regarding the extension of Ph.D. timelines

Source reference: para. 4
03

Law Applied

Ordinance No. 11 of Jiwaji University, which governs the Ph.D. programme and the prescribed timelines for thesis submission

Source reference: para. 2, 6

Statement identifying the discretionary and extraordinary powers vested in the Vice-Chancellor under the University Statutes and Ordinances to address cases where completion was hindered by unforeseen circumstances

Source reference: para. 6

Judicial precedent of Kirti Soni vs. Jiwaji University, Gwalior, which established that the Vice-Chancellor should exercise discretionary powers judiciously in similar factual contexts involving delays beyond the candidate's control

Source reference: para. 4
04

Reasoning

The Court noted that while the petitioner had already exhausted her re-registration period and technically failed to meet the 2023 deadline, the circumstances cited—specifically the global pandemic and maternal health issues—warranted a review under the Vice-Chancellor’s discretionary authority

Source reference: para. 5, 6

The Court observed that although no absolute right to relief existed on the merits due to the lapse of time, Ordinance No. 11 provides a framework for the Vice-Chancellor to consider such grievances

Source reference: para. 6

By referencing the Kirti Soni case, the Court emphasized the need for a judicious evaluation of the petitioner's specific hardships rather than a mechanical rejection based solely on the expiration of the stipulated period

Source reference: para. 4, 6
05

Holding

The High Court disposed of the petition without expressing an opinion on the merits, directing the Vice-Chancellor of Jiwaji University to consider the petitioner's case independently and strictly in accordance with Ordinance No. 11 and relevant Statutes

The Vice-Chancellor was ordered to determine if discretionary relief could be granted to allow the completion of the Ph.D. course, with the exercise to be completed within four weeks of receiving the certified order

Source reference: para. 6, 7

No costs were awarded

Source reference: para. 9
Madhya Pradesh High Court

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Smt. Mrinalini DwivedivsVice Chancellor Jiwaji

Madhya Pradesh High Court · July 14, 2026

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