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IN THE HIGH COURT OF KERALA AT ERNAKULAM
Nitin Jamdar, C.J., S.Manu, J.
Indian Institute Of Management – Appellant
Versus
Vikram Sriram, S/o.R.Sriram – Respondent
WA No. 791 of 2015
Decided on : 08-10-2024
(A) Indian Institute of Management Act - Regulations governing Executive Postgraduate Programme - The Appellant-Institute denied the certificate to the Respondent who failed in the second year of a two-year programme, emphasizing that academic standards must be maintained. (Paras 10, 16, 18)
(B) Academic Standards - Courts should refrain from interfering in academic matters unless fundamental rights are violated. The Appellant's decision to not issue a certificate post-failure is upheld. (Paras 17, 18)
Facts of the case:
The Respondent completed the first year of a two-year EPGDM program but failed in the second year, scoring insufficient grades and not submitting required assignments. The Appellant denied the request for a completion certificate based on these failures. (Paras 6, 10)
Findings of Court:
The Court upheld the Appellant's decision, emphasizing the importance of maintaining academic standards and the conditions outlined in the academic handbook. (Paras 18, 19)
Issues: Whether the Respondent is entitled to a completion certificate after failing in the second year and whether the Appellant's decision to deny the certificate was justified. (Paras 10, 18)
Ratio Decidendi: The Court ruled that academic institutions have the discretion to set and enforce standards, and students cannot claim completion of a program after failing to meet the requirements. (Paras 17, 18)
Result: The appeal is allowed, and the learned Single Judge's order is quashed. (Para 19)
JUDGMENT :
Nitin Jamdar, C. J.
The Appellant-Indian Institute of Management is aggrieved by the direction of the learned Single Judge to issue a certificate to the Respondent/Original Petitioner, a student, based on completion of the first year of a two year programme. According to the Appellant-Institute, having failed the second year of the Course, no direction could have been given to issue a certificate for the first year of the programme.
2. The Appellant-Institute conducts the Executive Postgraduate Programme (EPGP), a two-year postgraduate diploma program for the Executive Postgraduate Diploma in Management (EPGDM). Each academic year begins in September/October. There are four semesters. The program is divided into three modules : Foundation and Functional Core Courses, Electives and Functional Workshops, and an Integrated Capstone Course. Each Course follows a credit-based structure. One credit represents nine hours of contact sessions, and a full course of three credits requires 27 hours of classroom interaction.
3. The Academic Handbook for the 2011–2013 EPGDM, which is relevant to this petition, details the grading system, instructional tools, and academic requirements. There are various teaching methods, including computer-based simulations, class presentations, multimedia case analysis, video conferencing, and e-learning. Clause 4.4 of the Handbook specifies that the programme is delivered through two primary modes: the Interactive Learning (IL) Platform and in-campus modules. The IL Platform forms the core of the programme, utilizing two-way audio/video synchronous telecommunication to connect instructors with students remotely. Clause 4.2 specifies the elective requirements for the second year. Students have to choose 15 electives, each carrying 2 credits (equivalent to 18 hours of instruction), for a total of 270 instructional hours. Clause 5 provides details regarding the grading and evaluation system. To pass the Course, students must earn a grade above 'F' in the End Term Exam, with any failing grades recorded as 'F'. Clause 5.1 describes the 13-level grading scheme, ranging from A+ to F, and at the end of each Course, instructors assign letter grades to students. Clause 5.1.4 explains how the Term Grade Point Average (TGPA) is calculated by multiplying course credits with grade points and dividing the sum by the total credits for the term. Similarly, the Cumulative Grade Point Average (CGPA) is a composite measure of the student's overall academic performance across all terms, excluding non-credit courses.
4. For the award of the IIMK Diploma at the end of the programme, Clause 5.2.4 of the Handbook stipulates that students must meet several criteria: they must achieve a CGPA of at least 2.0 (equivalent to a C grade), have no more than 12 Deficit Credit Points (DCPs) during the second year, and ensure that all outstanding financial liabilities with the Institute are cleared. Clause 5.2.1 emphasises that both CGPA and DCP determine eligibility for promotion to the second year and for the award of the Diploma at the conclusion of the programme. If students do not meet the eligibility requirements under Clause 5.2.3 or 5.2.4, they can be terminated from the programme, however, Clause 5.2.6 allows students to apply for permission to repeat the year if they meet specific criteria. For those applying to repeat the first year, the CGPA should not fall below 2.0, and their DCPs must not exceed 18. For those applying to repeat the second year, the total DCPs must not exceed 12. The Chairperson-EPGP will assess the student’s academic performance and other relevant considerations, including disciplinary records, before granting approval to repeat the year.
5. Clause 10 of the Handbook permits students to withdraw temporarily from the programme for valid reasons, with the approval of the Chairperson-EPGP. A maximum break of one year is allowed, and the student must complete the interrupted academic year within two years fro
AI
Academic institutions maintain the discretion to enforce standards; students who fail to meet program requirements cannot claim certificates for completed courses.
A candidate's employment cannot be terminated based on allegations of overlapping degrees unless those degrees are declared null and void by the competent educational authority.
The court ruled that fragmented completion of required residency days at multiple institutions satisfies eligibility, given lack of explicit restrictions in the admission criteria, emphasizing the ne....
The court ruled that the failure of AIIMS to clearly communicate eligibility criteria for admission led to unjust denial of admission to meritorious candidates, emphasizing the need for clarity in ac....
Eligibility criteria for academic admissions cannot be altered after the admission process has commenced, ensuring fairness in selection.
Jurisdiction of High Court under Article 226 of the Constitution is couched in wide terms and exercise thereof is not subject to any restriction except restrictions expressly provided in the Article.
The exit condition in the admission notification was deemed directory, allowing the issuance of the Bachelor’s degree despite non-compliance.
The central legal point established in the judgment is the need to adhere to AICTE regulations for the approval of educational programs, and the discretionary jurisdiction of the High Court under Art....
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