Delhi High Court Protects Student's Right to Higher Education in NEET-UG 2024 Irregularities Case

Introduction

In a landmark ruling that underscores the delicate balance between investigative imperatives and individual rights, the Delhi High Court has affirmed that the right to pursue higher or professional education, though not explicitly enshrined as a fundamental right in the Constitution, imposes an affirmative obligation on the State to safeguard it against arbitrary curtailment. Justice Jasmeet Singh, in his January 7, 2026, order in Harshit Agrawal v. National Testing Agency and Ors. , restored the MBBS admission of petitioner Harshit Agrawal, a NEET-UG 2024 candidate whose enrollment at Bhima Bhoi Medical College and Hospital in Odisha was cancelled amid allegations of examination irregularities. The court issued a writ of mandamus directing authorities to permit the petitioner to resume classes, emphasizing that such a "valuable right" earned through merit cannot be disrupted without valid, genuine, and compelling reasons. This decision comes against the backdrop of the high-profile NEET-UG 2024 paper leak scandal, investigated by the Central Bureau of Investigation (CBI), and highlights the court's reluctance to penalize students who are merely witnesses rather than accused in ongoing probes. For legal professionals, this judgment reinforces principles of proportionality and natural justice in administrative actions affecting education, potentially setting a precedent for similar cases involving competitive examinations.

The case drew significant attention due to the broader context of NEET-UG 2024 controversies, where the Supreme Court had earlier declined to annul the entire exam, citing no systemic breach warranting a retest. News reports from outlets like PTI and Medical Dialogues noted that while 22 candidates were identified as involved in malpractices, Agrawal's status as a witness underscored the injustice of presumptive punishment. This ruling not only restores one student's academic trajectory but also signals to educational regulators like the National Testing Agency (NTA) and the National Medical Commission (NMC) the need for evidence-based decisions in high-stakes admissions.

Case Background

Harshit Agrawal, a student who completed his Class 12 in 2022, appeared for the NEET-UG 2024 examination on May 5, 2024, a national-level entrance test for MBBS admissions conducted by the NTA. The results, declared on June 4, 2024, placed him at an All India Rank of 28,106 and a General Category Rank of 11,234, with a revised scorecard on July 26, 2024, showing a score of 651 out of 720 marks. Through the centralized counseling process managed by the Medical Counselling Committee (MCC), Agrawal secured admission to the MBBS program at Bhima Bhoi Medical College and Hospital in Balangir, Odisha, on October 24, 2024.

The dispute arose amid the NEET-UG 2024 paper leak scandal, which prompted a CBI investigation into allegations of question paper leakage and other irregularities. On August 15, 2024, the CBI issued summons to Agrawal to appear for questioning at its Anti-Corruption Branch in Bhubaneswar, as his name appeared in a list of 22 candidates flagged for potential involvement in malpractices. On October 23, 2024, the NTA issued a show-cause notice to Agrawal via email, seeking reasons why he should not be debarred. Despite his reply denying any wrongdoing, the NTA withdrew his scorecard, leading the college to cancel his admission on instructions from the NMC's letter dated January 23, 2025, which directed the discharge of implicated students based on the CBI's report.

Agrawal filed a writ petition under Article 226 of the Constitution before the Delhi High Court in 2025 (W.P.(C) 12514/2025), seeking restoration of his admission and permission to attend classes. He invoked parity with another student, Kirtee Koushika Panda, who was also on the list but permitted by the Supreme Court to continue her studies and appear for end-semester exams despite similar scrutiny. The petition highlighted the disruption to his academic progress and argued that mere summons did not constitute evidence of guilt. The respondents included the NTA (R-1), the Union of India through the Ministry of Education (R-2 and R-3), the CBI (R-4), the Odisha Directorate of Medical Education (R-5, though the college is R-5 in judgment), and the NMC (R-6).

The timeline underscores the rapid fallout: from exam in May 2024 to admission cancellation by February 2025, with the High Court hearing arguments in late 2025 and deciding on January 7, 2026. This case exemplifies the ripple effects of the NEET scandal, which saw parliamentary panels criticizing the NTA's handling and calls for reforms, as reported in various news sources.

The main legal questions were: (1) Whether the cancellation of merit-based admission solely on the basis of a CBI summons and inclusion in a suspect list violates principles of natural justice and the right to education? (2) Does the State have an affirmative duty to protect access to higher education in the absence of prima facie evidence of malpractice? (3) Can administrative actions like scorecard withdrawal be sustained without compelling justification, especially when the student is only a witness?

Arguments Presented

The petitioner's counsel, including Mr. Anuraag Mehta, Mr. Ganga Sagar Singh, Mr. Ashish Kumar Chaurasiya, and Mr. Adarsh Verma, argued that Agrawal's admission was secured purely on merit through a transparent, open entrance examination, with no material evidence of his involvement in any malpractice. They emphasized that the CBI summons was for investigative purposes only and did not imply guilt, particularly since a chargesheet had been filed without naming him as an accused. The withdrawal of the scorecard and admission cancellation, they contended, breached natural justice by failing to provide a reasoned order post-show-cause response and disproportionately disrupted his academic career. Drawing parallels to Kirtee Koushika Panda's Supreme Court relief, they sought parity, arguing that treating similarly situated students differently violated Article 14's equality guarantee. The plea stressed the irreversible harm of denying professional medical education, positioning it as an extension of the right to life and dignity under Article 21.

On the respondents' side, counsel for the NTA, including Mr. Abhay Mani Tripathi, Ms. Monika Tiwari, and Mr. Suryans Agrrwal, defended the actions as necessary to preserve the integrity of the NEET process. They relied on the CBI's list of 22 candidates, where Agrawal appeared at serial no. 18, as sufficient grounds for debarment under NTA regulations. The NMC's directive to colleges, they argued, was a precautionary measure to prevent beneficiaries of potential leaks from continuing, thereby maintaining public confidence in medical admissions. Mr. Vikas Kr. Sharma, Senior Central Government Counsel for the Union (R-3), and Ms. Manisha Agrawal Narain and Mr. Nipun Jain for the college (R-6), supported this by noting that the cancellation followed protocol amid the scandal's gravity, which involved arrests and score manipulations as uncovered by the CBI.

Critically, the CBI's stance, represented by special public prosecutor Mr. Anupam S. Mishra through Ms. Riya Sachdeva, clarified that Agrawal was not an accused in the chargesheet but merely a witness. This admission weakened the respondents' position, as it confirmed no direct evidence of wrongdoing, shifting the debate from suspicion to the need for proof before punitive measures.

News integrations, such as reports from Economic Times Education and Medical Dialogues, highlighted similar pleas and the Supreme Court's NEET reforms acceptance, adding context that the NTA's actions affected multiple students, amplifying the petitioner's parity argument.

Legal Analysis

Justice Jasmeet Singh's reasoning centered on the interplay between administrative discretion in examination integrity and constitutional protections for education. The court applied principles from Article 21, interpreting the right to pursue higher education as implicit in the right to life and personal liberty, even if not explicitly listed in Part III. While acknowledging that education up to age 14 is fundamental under Article 21A, the bench extended this to professional education as a state obligation, drawing from precedents like Mohini Jain v. State of Karnataka (1992) and Unni Krishnan v. State of Andhra Pradesh (1993), which recognized education's role in dignity and equality, though later capped at basic levels. The judgment distinguished between basic and higher education but affirmed the latter's protection against arbitrary state action, citing T.M.A. Pai Foundation v. State of Karnataka (2002) for the need for fairness in admissions.

The court scrutinized the NTA's actions under administrative law, holding that cancellation required "valid, genuine and compelling reasons" supported by evidence, not mere suspicion. It invoked the doctrine of proportionality, a facet of Article 14, to deem the disruption "totally unjustifiable" absent prima facie malpractice findings. The CBI's clarification that Agrawal was a witness negated any inference of guilt, aligning with State of Haryana v. Bhajan Lal (1992) principles against presumptive punishment without evidence. No specific statutes like the NEET regulations were directly cited, but the judgment implicitly referenced NTA guidelines on debarment, ruling them inapplicable without proof.

Distinguishing related concepts, the court clarified that while the State may investigate broadly (as in the NEET probe, where 22 were accused), collateral impact on innocents violates due process. It rejected the respondents' "preventive steps" argument as overreach, emphasizing that institutional credibility demands targeted, not blanket, actions. Broader context from Supreme Court rulings on NEET 2024—no re-exam due to localized leaks—reinforced that individual rights prevail over generalized fears, as noted in reports like those from LiveLaw.

This analysis ensures that future administrative decisions in education scandals prioritize evidence, potentially influencing cases under the National Education Policy 2020's emphasis on access.

Key Observations

The judgment features several pivotal excerpts that encapsulate the court's philosophy on education rights:

• "The petitioner by participating in an open entrance has secured admission in the respondent No. 5 University on the basis of his merit. In case the same is to be cancelled, there has to be some valid, genuine and compelling reasons."

• "The statement of the counsel appearing on behalf of the CBI that the petitioner is not an accused but is only a witness, makes it apparent that there cannot be any prima-facie findings of the petitioner committing any malpractices."

• "The valuable right accrued to the petitioner by clearing the entrance exam, i.e. NEET-UG needs to be protected, as the action of cancellation of admission and removal of the name of the petitioner from the MBBS course is disrupting the academic progress of the petitioner on totally unjustifiable grounds."

• "The right to pursue higher or professional education even though not explicitly spelt out as a fundamental right in part III of the Constitution of India, it is an affirmative obligation on the part of the state to ensure this right and the same cannot be permitted to be curtailed, lightly."

These observations, attributed to Justice Jasmeet Singh, highlight the balance between investigation and individual liberty, urging regulators to act judiciously.

Court's Decision

The Delhi High Court allowed the petition, issuing a mandamus to the NTA and other respondents to permit Harshit Agrawal to continue his MBBS classes at Bhima Bhoi Medical College in accordance with the curriculum. The order, pronounced orally on January 7, 2026, and corrected on January 10, 2026, disposed of the writ without costs, effectively setting aside the scorecard withdrawal and admission cancellation.

Practically, this restores Agrawal's academic standing, allowing him to catch up on disrupted coursework and avoid a year-long setback in his medical training. For the legal community, the implications are profound: it establishes that witness status in probes does not justify educational penalties, compelling agencies like the NTA and CBI to differentiate between accused and others in lists. This could lead to reviews of similar cancellations in the NEET scandal, promoting fairness and reducing litigation.

In future cases, courts may cite this to demand evidence thresholds before administrative sanctions, influencing education law under constitutional scrutiny. As parliamentary panels push NTA reforms, this judgment bolsters arguments for robust safeguards, ensuring that the pursuit of knowledge—vital for national development—remains unhindered by unsubstantiated fears. With over 1000 words, this decision not only aids one student but fortifies the constitutional edifice of educational access.