The court upheld Pharmacy Council regulations regarding student admissions, confirming that unauthorized admissions cannot be regularized, thus emphasizing the importance of maintaining academic standards in pharmacy education.

JUDGMENT :

VIBHU BAKHRU, CJ.

1. The appellant has filed the present appeal impugning an order dated 30.06.2025 passed by the learned Single Judge of this Court in W.P.No.7679/2025 (EDN-RES), whereby the said petition was dismissed.

2. The appellant had filed the said petition, inter alia, praying for issuance of a writ of mandamus or any other appropriate order or direction to respondent No.1 [hereafter 'the University'] and respondent No.2 [hereafter 'the College'] to recognize and reinstate the appellant to the academic batch of 2024-2025 of the two year course of Masters in Pharmacy (Drug Regulatory Affairs) [M.Pharma - DRAF].

3. At the material time, the appellant was a first year student of the M.Pharma-DRAF course and had been enrolled in the College under the management quota.

4. The appellant's enrolment was cancelled and he was not permitted to attend the classes with effect from 15.02.2025. The College had admitted one student beyond the permissible sanction and therefore, was required to reduce the strength by one student. The appellant claimed that he could not have been removed from the College as he was not at fault. The appellant sent a representation to the University by an email dated 17.02.2025, requesting that he be reinstated as student in the batch of 2024-2025.

5. The appellant had contended that his removal was unjustified, arbitrary and unlawful. The appellant also addressed a complaint to the University Grants Commission [UGC] against his removal.

6. Since the appellant's representations were not accepted, the appellant filed the writ petition on the ground that respondent No.4 [Pharmacy Council] had unequivocally declined to grant any relaxation for regularising excess admission and the College could not admit students beyond the limit as prescribed.

7. The learned counsel for the appellant had earnestly contended that the appellant's future is at stake and he would lose a year if the relief, he sought for is not granted. He also submitted that since the appellant had been enrolled in the College, he could not have been removed for reasons that were not attributable to him. Thus, if the College had enrolled students in excess of the permissible sanction, the intake of number of students could be temporarily enhanced. In the alternative, he submitted that in the event the admission of one student was required to be deleted, the admission granted to respondent No.3 was required to be cancelled as she was admitted after the admission was granted to the appellant. He contended that the removal of the appellant was thus, arbitrary and liable to be struck down.

8. First and foremost question to be addressed is whether the intake of number of students can be relaxed.

9. We have given our anxious thought to the said question considering the appellant's predicament. We may note that initially the Pharmacy Council was not arrayed as a respondent in the writ petition, however, it was contented that the appellant's admission has been cancelled on account of the College admitting the students in excess of the limit as sanctioned by the Pharmacy Council. In view of the same, the Pharmacy Council was added as a respondent.

10. At the hearing held on 01.04.2025 before the learned Single Judge, it was contented on behalf of the Pharmacy Council that in the