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2026 Supreme(SC) 8

SUPREME COURT OF INDIA
VIKRAM NATH, AUGUSTINE GEORGE MASIH, JJ.
Pratima Das – Appellant
Versus
State Of Himachal Pradesh And Ors. – Respondents
Civil Appeal No. 63 of 2026 (Arising out of SLP(Civil) No. 15180 of 2025)
Decided On : 06-01-2026

Advocates appeared:
For the Petitioner(s): Mr. Prashanto Chandra Sen, Sr. Adv. Ms. Muskan Nagpal, Adv. M/s Mitter & Mitter Co., AOR
For the Respondent(s): Mr. Abhishek Gautam, AOR Mr. Vivek Kumar, Adv. Mr. Rajender Kumar, Adv. Mr. Bhupender Singh, AOR Mr. Indrajeet Singh, Adv. Mr. Rituparn Uniyal, AOR

The university is responsible for correcting clerical errors that affect students' access to academic documents, reaffirming the principle that students should not suffer due to administrative mistakes.

Headnote:(A) UGC Act, 1956 - Manav Bharti University (Establishment & Regulation) Act, 2009 - Issue of marksheets - The appellant has completed the BA.LLB program but was initially denied marksheets due to clerical errors; the Court emphasized the university's responsibility for record accuracy and student welfare, concluding that no factual dispute warranted further litigation. (Paras 18-22)

(B) Administrative errors - The Court recognized that the misplacement of the appellant's name in the admission disclosure list constituted a clerical and inadvertent mistake, not a substitution or deletion of the petitioner’s actual admission. (Paras 8, 20)

Facts of the case:
The appellant completed BA.LLB from MB University, facing delays in obtaining academic documents due to errors in the admission publication and ongoing investigations into the university. Students collectively filed grievances leading to a Public Interest Litigation concerning their situation.

Findings of Court:
The Court found no fault on the appellant's part for the delays in obtaining documents; ordered immediate issuance of marksheets and degree.

Issues: The main legal questions concerned the mishandling of academic records and the responsibilities of the university versus student accountability.

Ratio Decidendi: The court held that the university must correct clerical errors harming students' futures and must ensure they can pursue further education or careers without undue delay.

Result: Appeal allowed; MB University directed to issue the required documents within four weeks.

Judgement Key Points

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Table of Content
1. appeal for release of academic documents (Para 2 , 3 , 4 , 5)
2. high court's intervention in student grievances (Para 6 , 7 , 8 , 9)
3. appellant's hardships due to document non-issuance (Para 10 , 12 , 13)
4. university's admission error and appellant's innocence (Para 16 , 17 , 18 , 20)
5. court orders issuance of marksheets and degree (Para 21 , 22 , 23)

JUDGMENT :

AUGUSTINE GEORGE MASIH, J.

1. Leave granted.

2. The Appellant has preferred this appeal seeking release of her marksheets of the 5th to 10th semester and degree in law having graduated from Manav Bharti University (hereinafter “MB University”) on completion of the BA.LLB programme batch of 2017-2022.

3. The Appellant took admission in MB University under the Admission no. R17BALLB0033 and Registration No.MBU-2017-0536 for the session batch of 2017-2022 and was issued a Bonafide Certificate dated 30.08.2017 in this regard.

4. On registration of a First Information Report, an investigation ensued against MB University on the allegation of sale of fake degrees. A Special Investigation Team was set up which seized the complete records of MB University in the year 2019. Since the matter was pending adjudication before the Court of Additional District and Sessions Judge, Solan, the students of the University, including the Appellant, were suffering, as they were unable to procure their academic documents. This resulted in grave prejudice and hardship due to inability to pursue their further academic career and adversely affected future professional prospects after graduation. The Appellant was only issued marksheets for the first four semesters.

5. Aggrieved by the inability of MB University to release such documents, for the reasons as stated above, students from different departments of batches of 2019, 2020 and 2021 jointly wrote a letter to the Chief Justice of the High Court of Himachal Pradesh highlighting their grievances and frustrations. The said letter was ordered by the Court to be registered as a Public Interest Litigation and numbered as CWPIL No.22 of 2022.

6. In order to address the grievance of the students, the High Court of Himachal Pradesh, proceeded to direct MB University to constitute a committee for the purpose of verification and release of the photocopies of the relevant documents of the students. Certain parameters and criteria were set out for supplying these documents, i.e.; whether the courses in which the students were found registered were duly approved by the UGC and within the allotted seats for MB University; whether the record of the student found reflected in the Green register and Admission disclosure; whether the data had been sent for the session for which the student was enrolled, and whether the record of the examination reflects the entry of the student along with the above parameters. It was further observed that students whose admission and registration year would be disputed would not be considered for supply of documents.

7. When the Appellant herein approached MB University for procuring her documents, she was informed that though she was found to be enrolled in the green register under admission no. R17BALL0033, her name was not reflected in the admission disclosure list for the session 2017-2018. Instead, the name of one Mr. Ayaan Narwal was mentioned against her admission number. Due to such circumstances, her documents could not be issued to her.

8. Aggrieved by the non-acceptance of her request for supply of documents, the Appellant approached the High Court by filing CWP No.1480/2024, which was disposed of with a direction to the custodian of the records to decide her case after giving her an opportunity of being heard. The Appellant, in pursuance thereto, submitted representation to the Superintendent of Police, Solan, Himachal Pradesh, who had the custody of the records of MB University, for issuance of her unsupplied marksheets. This was rejected on the ground that her name did not reflect in the admission

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