1. Admission to medical courses under sports quota — Dispute over expansion of eligibility criteria from Classes XI and XII to include Classes IX and X mid-process. (Para 2 , 3 , 5 , 6 , 7 , 8 , 11 , 12 , 13 , 14 , 15 , 16 , 19 , 23 , 24 , 25 , 41 )
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2026 Supreme(SC) 24
SUPREME COURT OF INDIA
SANJAY KUMAR, ALOK ARADHE, JJ.
Divjot Sekhon – Appellant
Versus
State of Punjab And Others – Respondents
Civil Appeal No. 67 of 2026 (@ Special Leave Petition (Civil) No. 23112 of 2024) with Civil Appeal No. 68 of 2026 (@ Special Leave Petition (Civil) No. 28046 of 2024) & Civil Appeal No. 69 of 2026 (@ Special Leave Petition (Civil) No. 20137 of 2025)
Decided On : 06-01-2026
Advocates appeared:
For the Appellant : SLP(C) No. 23112/2024 : Ms. Misha Rohatgi, AOR, Mr. Suneet Pal Singh Aulakh, Adv., Mr. Nakul Mohta, Adv., Mr. Ayush Kashyap, Adv., Mr. Amulya Upadhyay, Adv.; SLP(C) No. 28046/2024 : Ms. Jyoti Mendiratta, AOR; SLP(C) No. 20137/2025 : Mr. B.K. Satija, AOR
For the Respondents: For State of Punjab : Mr. Siddhant Sharma, AOR, Mr. Vikram Choudhary, Adv.; For BFUHS : Mr. Nitin Kaushal, Adv., Mr. Manoj Pandey, Adv., Mr. Anuj Tyagi, AOR, Ms. Shreelekha Vyas, Adv., Ms. Tanya Swarup, AOR
For the Appellant : SLP(C) No. 23112/2024 : Ms. Misha Rohatgi, AOR, Mr. Suneet Pal Singh Aulakh, Adv., Mr. Nakul Mohta, Adv., Mr. Ayush Kashyap, Adv., Mr. Amulya Upadhyay, Adv.; SLP(C) No. 28046/2024 : Ms. Jyoti Mendiratta, AOR; SLP(C) No. 20137/2025 : Mr. B.K. Satija, AOR
For the Respondents: For State of Punjab : Mr. Siddhant Sharma, AOR, Mr. Vikram Choudhary, Adv.; For BFUHS : Mr. Nitin Kaushal, Adv., Mr. Manoj Pandey, Adv., Mr. Anuj Tyagi, AOR, Ms. Shreelekha Vyas, Adv., Ms. Tanya Swarup, AOR
Admission criteria for educational institutions must be firmly established prior to the application process to ensure transparency and prevent arbitrariness in selection, especially in competitive fields.
Headnote:(A) Admission to MBBS/BDS Courses - Sports Quota - Prospective modification prohibited - Court reiterates that admission criteria must be established prior to the commencement of the admission process to ensure transparency and prevent arbitrariness. The change to include achievements from earlier classes (IX and X) contradicted existing policies, leading to claims of favoritism. (Paras 18, 24, 36, 38)
(B) Procedural Integrity - The Court emphasized the principle that rules cannot be altered once the process has commenced, safeguarding fairness in admissions and preserving expectations. (Paras 18, 41)
Facts of the case:
The appeals are by medical college aspirants under the sports quota challenging the broadening of criteria for admission to include sports achievements from classes IX and X, which was not in alignment with previously established norms. The policy change was influenced by private interests which resulted in disadvantage to other candidates.
Findings of Court:
It was found that the process for MBBS/BDS admissions for session-2024 was manipulated after the application had begun, leading to inequitable advantages to certain candidates.
Issues: The main issues were the legitimacy of modifying admission criteria mid-process and the impact of alleged favoritism due to the influence of a coach on admissions.
Ratio Decidendi: The court ruled that altering the criteria midstream undermines procedural fairness and transparency, thus violating principles of equality and justice.
Result: Appeals allowed with specific seats directed to be reallocated to rightful candidates.
Legal Category Hierarchy
Table of Contents
2. Appellants challenge mid-process alteration of selection criteria as arbitrary — State contends government notifications supersede prospectus and change serves sportspersons' welfare. (Para 8 , 9 , 10 , 11 , 12 , 21 )
3. Policy change was prompted by undisclosed private interest — Lack of transparency and inconsistent application across courses indicate arbitrariness and nepotism. (Para 15 , 16 , 17 , 19 , 20 , 22 , 23 , 24 , 25 , 26 , 28 , 29 , 30 , 33 , 34 , 35 , 36 , 37 )
4. Selection criteria cannot be altered after the process has commenced — Transparency in admission processes is essential to prevent arbitrariness and nepotism. (Para 18 , 31 , 32 )
5. Policy modification quashed — Appellants accommodated in government seats vacated by beneficiaries of the illegal change — Liberty granted to session 2025 appellants to re-approach High Court. (Para 38 , 40 , 42 )
6. Can selection criteria be changed after the admission or recruitment process has started?
No. The rules of the game, meaning the criteria for selection, cannot be altered by the authorities once the selection process has commenced. This principle ensures fairness and prevents the process from being manipulated to suit specific interests. (Para 18 )
7. What is the legal standard for the State to change its policy under Article 14?
While the State has the discretion to change policy, any sudden change without valid reasons is viewed with suspicion. Such changes must be fair, reasonable, and not arbitrary or driven by ulterior motives to satisfy the mandate of Article 14. (Para 31 )
8. How does the doctrine of legitimate expectation apply to the actions of public authorities?
Citizens trust the State to act in a consistent, transparent, and predictable manner. Principles of good administration require that decisions of public authorities withstand these tests to avoid being regarded as arbitrary and violative of Article 14. (Para 32 )
9. Does a lack of transparency in the formulation of admission norms affect their legal validity?
Yes. Leaving admission norms elastic and allowing mid-stream changes without full disclosure enables arbitrariness and nepotism. Transparency is paramount to ensure fair play and prevent the backdoor entry of favoritism in an egalitarian State. (Para 17 , 36 )
JUDGMENT :
SANJAY KUMAR, J.
1. Leave granted.
2. These appeals arise out of separate orders passed by the High Court of Punjab and Haryana at Chandigarh dismissing the writ petitions filed by the appellants. The first of the appeals pertains to Divjot Sekhon. Her writ petition in CWP-21051-2024 was dismissed by a Division Bench of the High Court on 11.09.2024. Her prayer therein was to quash the email dated 16.08.2024 sent by Baba Farid University of Health Sciences, Faridkot1[For short, ‘the University’], whereby candidates applying for admission to MBBS/BDS courses under sports quota in session-2024 were asked to submit their certificates/achievements of any class/year instead of just Classes XI and XII. She also challenged the merit list dated 23.08.2024 of candidates admitted to MBBS/BDS courses under sports quota, that placed Kudrat Kashyap and Mansirat Kaur, respondent Nos. 4 and 5, at high positions therein on the strength of their sports achievements in Classes IX and X.
3. The next appeal is of Shubhkarman Singh, another MBBS aspirant under sports quota during session-2024. On 12.09.2024, the same Division Bench dismissed his writ petition in CWP-23083-2024, following its decision in Divjot Sekhon’s case, a day earlier. His prayer was on the same lines as Divjot Sekhon’s. In addition thereto, he assailed the Addendum dated 03.09.2024, whereby the University informed all National Eligibility-cum-Entrance Test (Undergraduate) [NEET UG-2024] aspirants who applied under sports quota that sports achievements during Classes XI and XII was misprinted in the Prospectus and that they were told via email dated 16.08.2024 to submit all their sports achievements during any class/year/session in person on 19.08.2024 (upto 3 PM).
4. The email dated 16.08.2024, issued by the Admission Branch of the University, was addressed to all the candidates who had applied under sports quota and they were informed that, as per Punjab Government’s Notification for admission to MBBS/BDS courses under NEET UG-2024, the clause pertaining to sports category read: ‘Credit and admission shall be made on the basis of inter-se merit determined on the basis of gradation (Category A/B/C) as per sports policy notified by Department of Sports & Youth Services, Government of Punjab’. The candidates were told that, as per the above clause, it was not compulsory to submit only sports achievements of 10+1 & 10+2 Classes and they were supposed to submit all their sports achievements made during any class/year. They were told that if they wanted to submit any more documents in support of their claim under sports category, which they had not submitted earlier, they could submit the same in person on 19.08.2024 upto 3 PM. Thus, the addendum dated 03.09.2024, issued post facto, was only an affirmation of the email dated 16.08.2024.
5. The last appeal pertains to Agrima Mann, Gauranshi Dhingra and Navreet Singh, aspirants for admission to MBBS/BDS courses under sports quota for the next year, i.e., during session-2025. They filed CWP-19735-2025 assailing Clauses 15(v) and 16(v) of the Notification dated 09.08.2024, published on 17.06.2025, for admission to MBBS/BDS courses through NEET UG-2025. The impugned clauses related to 1% reservation of seats under sports quota, whereby credit was sought to be given to sports achievements during any academic year without restriction. Their prayer was that the benefit should be restricted to the achievements in Classes XI and XII only and that there was no justification in perpetuating the criteria that was adopted during Covid-19 pandemic. They sought a direction to the authorities to restore the policy decision/ criteria which existed prior to session-2023 in respect of admissions to MBBS/BDS courses for session-2025. In the alternative, they sought a direction to the authorities to implement the changed policy decision/ criteria in a staggered manner so as to not take the existing aspirants by surprise. This writ petition was dis
