Madras High Court

Writ petition challenging validity of long-standing educational degree based on mere presumption of employment is unsustainable.

M. Manickam vs State of TamilNadu

Madras High CourtJUDGMENT: July 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellant/petitioner filed a Writ Petition (W.P. No. 47481 of 2025) challenging the validity of a Master of Engineering (M.E.) degree obtained by the 9th Respondent from Anna University 19 years prior.

Source reference: p. 3, para. 2

The appellant contended that the 9th Respondent obtained the degree while in service and not as a regular student.

Source reference: p. 3, para. 2

The Writ Court dismissed the petition on 08.12.2025.

Source reference: p. 2

The appellant subsequently filed the present Writ Appeal to set aside that order.

Source reference: no citation
02

Issues

Whether the Writ Court was justified in dismissing the petition challenging the validity of a degree obtained 19 years ago based on a lack of admissible evidence.

Source reference: p. 3, para. 3
03

Law Applied

A writ petition cannot be entertained based on mere presumption; a petitioner must produce acceptable and admissible evidence before the employer to establish a cause for further legal action.

Source reference: p. 3, para. 3

Degrees obtained via evening colleges approved by the All India Council for Technical Education (AICTE), such as those conducted by Anna University, are recognized as regular degree courses even if the student is employed.

Source reference: p. 3, para. 2
04

Reasoning

The court found that the appellant failed to provide any "acceptable evidence" to the employer to substantiate the claim that the degree was invalid.

Source reference: p. 3, para. 3

The court observed that the appellant’s case rested solely on the "presumption" that the 9th Respondent could not have undergone a regular M.E. course while being employed.

Source reference: p. 3, para. 3

The court highlighted that during the relevant period, AICTE-approved evening college programs existed and were considered regular degrees.

Source reference: p. 3, para. 2

Given the 19-year delay since the degree was awarded and the absence of prima facie evidence of irregularity, the court held that it could not probe into the validity of the degree in the present proceedings.

Source reference: p. 3, para. 3
05

Holding

A Writ Petition cannot be entertained based on mere presumptions regarding a respondent's employment status during their studies.

The High Court dismissed the Writ Appeal, upholding the Writ Court's decision to dismiss the original petition. No costs were awarded, and the connected Miscellaneous Petition was closed.

Source reference: p. 4
Madras High Court

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M. ManickamvsState of TamilNadu

Madras High Court · July 22, 2026

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