Academic institutions retain discretionary authority to enforce performance standards and promotion requirements, provided the application of internal rules is not perverse or arbitrary. Judicial review of such academic decisions is limited to verifying that the process followed proper jurisdictional and legal standards.

JUDGMENT :

TAPABRATA CHAKRABORTY, J.

1. The present appeal has been preferred challenging an order dated 18^th February, 2026 passed by the learned single Judge in two writ petitions being WPA 24155 of 2025 and WPA 940 of 2026.

2. The writ petitioner, namely, Harish was enrolled in the post-graduate management programme (hereinafter referred to as the MBA programme) for the two academic years 2024-2026 consisting of six Terms being the 61st batch at the Indian Institute of Management, Kolkata (in short, IIMC). His application was in the category of Persons with Disabilities (in short, PwD) as he was suffering major psychiatric disorder, namely, Schizophrenia. In Term-I and Term-II of the first academic year, he could not appear in the mid-term examinations due to his ailments. However, he could complete the said Terms having emerged to be successful in the make-up examinations and thereafter he completed Term-III with 60% attendance but IIMC arbitrarily reduced the Cumulative Grade Point Average (in short, CGPA) from 4.58 to 3.83 in Term-I, from 4.20 to 3.77 in Term-II and from 4.34 to 3.40 in Term-III. Thereafter as he was not being allowed to attend the classes pertaining to Term-IV in the second year, he submitted repeated representations and in response thereto, by a letter dated 22^nd April, 2025 he was intimated that as his CGPA was below minimum qualifying CGPA of 4.5 as required for promotion to second year, the Academic Council in its meeting dated 2nd April, 2025 had decided to allow him to repeat the first year MBA Programme with the 62nd batch and to deposit an amount of one lakh. Pursuant thereto, he paid the said amount on 13^th May, 2025. Subsequent thereto, Harish’s parents again approached the authorities of IIMC with medical fitness certificate of Harish on 24^th July, 2025 as he was not being granted conditional promotion to the second year but by a letter dated 26th July, 2025 it was intimated that his case had been reviewed by the Academic Council in its meeting dated 25th July, 2025 and it was resolved that as per the prevailing Rules and Regulations of MBA Students (hereinafter referred to as the Rules) he has to resume his studies in Term-I of the (AY 2025-26) with the MBA 62^nd batch. Aggrieved thereby Harish preferred the writ petition in WPA 24155 of 2025 challenging inter alia the reduction of CGPA in Term-I, II and III for the first year MBA Programme. In the said writ petition an interim order was passed on 14^th October, 2025 directing the authorities to allow Harish to attend the next session Term-V commencing from 21^st October, 2025. Pursuant to the said order, Harish was allowed to re-join the classes on and from 21^st October, 2025 but as he could join the Term–V classes mid-way, he could not acquire the required percentage. Surprisingly thereafter as he was not allowed to take part in the placement process for the 61^st batch which commenced from the first week of December, 2025, he was constrained to file another writ petition being WPA 940 of 2026. In the midst thereof, an application for vacating the interim order was also filed by IIMC and both the writ petitions along with vacating application were finally heard and disposed of by the order impugned in the present appeal.

3. In the final order dated 18^th February, 2026 the learned single Judge arrived at a finding that the overall performance of Harish was poor and the decision of IIMC denying him conditional promotion to the second year of the 61^s