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2025 Supreme(Raj) 2561

HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR
Sameer Jain, J.    
Jai Rao S/o Shri Harish Chand Rav - Petitioner
Versus
State Of Rajasthan, Through Its Principal Secretary, Department Of Higher Education - Respondent
S.B. Civil Writ Petition No. 11354 of 2025, S.B. Civil Writ Petition No. 11789 of 2025, S.B. Civil Writ Petition No. 11800 of 2025, S.B. Civil Writ Petition No. 13904 of 2025, S.B. Civil Writ Petition No. 14689 of 2025
Decided On : 19-12-2025

Advocates Appeared:
For the Petitioner: Dr. Abhinav Sharma (Amicus Curiae), with Mr. Akshaya Varma & Mr. Rahul, Sharma, Ms. Puja Sharma, Mr. Vishal Choudhary, Mr. Shantanu Pareek, Mr. Navin Kumar Yadav, Mr. Tushar Panwar with, Mr. Rohit Mahrada, Mr. Tushar Goyal, Mr. Mukul Rao, Mr. Deepak Tilwania, Mr. Anil Kr. Kasana, Mr. Anish Bhadala, Mr. Rishabh Bhidasra
For the Respondent: Mr. Rajendra Prasad, AG with Ms. Dhriti Ladha, Ms. Harshita Thakral, Mr. Sheetanshu Sharma, Mr. Tanay Goyal, Mr. S.S. Naruka, AAG with, Mr. Jitendra Kumar Takar, Mr. Anshuman Singh, Mr. Tanishq Aditya Parmar, Mr. A.K. Sharma, Sr. Adv. with, Mr. Rachit Sharma, Mr. Madhav Dhadhich

The court reaffirmed that student union elections are a constitutional right tied to educational integrity and must comply with established guidelines to balance democratic participation and academic discipline.

Headnote:(A) Constitution of India - Article 226 - Conduct of Student Union Elections - Petitioners sought directives for non-conduct of student elections violating Lyngdoh Committee recommendations; Court recognizes elections as integral to education and directs adherence to guidelines. - Mutatis mutandis, this judgment is applicable to all connected petitions. (Paras 1-2)

(B) Right to Education - The right to conduct student elections is tied to the fundamental right of students to form associations under Article 19(1)(c) and relevant judicial precedents reinforce this point. (Paras 4, 13-14)

(C) Administrative Discretion - The respondents are obliged to hold elections based on previous judicial determinations and to ensure student representation, notwithstanding claims of academic disruption. (Paras 30-31, 41)

(D) Compliance with Guidelines - Directions issued for timely conduct of elections while maintaining academic integrity. The directive aims to balance student democracy with academic discipline and is rooted in larger public interest. (Paras 45-60)

Findings of Court:
Due to failure to issue notification for student elections and the necessity of following established mandates, the court emphasized accountability and prospective compliance with guidelines.

Issues: The legal obligation of universities to conduct student union elections and the resultant implications of administrative reasons for not holding elections.

Ratio Decidendi: The court ruled that the failure to hold student elections undermines fundamental constitutional principles and established guidelines must be adhered to unless there are compelling reasons, which were not demonstrated in the case.

Result: Writ petitions dismissed without prejudice to future claims, particular emphasis on guidelines for future compliance with respect to student elections and the balance between academic priorities and student rights.

Judgement Key Points

Certainly. Based on the provided legal document, here are the key points summarized:

  1. The court emphasized that student union elections are a fundamental and integral part of higher education, essential for democratic participation, leadership development, and the holistic growth of students (!) (!) (!) (!) (!) .

  2. The right to hold student union elections is recognized as a fundamental right, supported by judicial precedents, and is connected to students' rights to form associations and participate in democratic processes (!) (!) (!) (!) .

  3. The Lyngdoh Committee recommendations, which set guidelines for conducting student elections, have been accepted and are considered binding. These guidelines require elections to be held annually within a specified timeframe after the academic session begins (!) (!) .

  4. The university's failure to issue notifications for the 2025–26 student union elections, despite the academic session having commenced, constitutes a violation of constitutional and legal obligations. This inaction is viewed as arbitrary and unconstitutional (!) (!) .

  5. The court recognized that the conduct of elections is necessary for the democratic rights of students but must be balanced against the university’s primary academic objectives. The disruption caused by elections should not interfere with the core educational mission (!) (!) .

  6. The court highlighted that the university's infrastructure and resources are routinely used for external elections, such as parliamentary and local body elections, and that similar facilities should be available for student elections without causing undue academic disruption (!) (!) (!) .

  7. The court dismissed the petitions due to lack of locus standi, as the petitioners did not demonstrate proper authorization or represent the broader student body, and because they had not exhausted internal remedies before approaching the court (!) (!) (!) .

  8. The court also found the petitions to be premature, as no formal grievance or decision regarding non-conduct of elections had been made by the university authorities. The petitions were filed before any adverse administrative action or decision, making them unsuitable for judicial review at that stage (!) (!) .

  9. The court directed that any grievances related to the non-conduct of student elections should be first addressed through the university’s internal mechanisms, such as the Dean of Student Welfare or the designated election committees, before approaching the courts (!) (!) .

  10. The court issued prospective directions to ensure future conduct of student elections in accordance with established guidelines, emphasizing the importance of maintaining academic continuity, transparency, and institutional discipline. These directions include setting election calendars, ensuring proper use of infrastructure, and avoiding politicization of the campus environment (!) (!) (!) (!) (!) .

  11. The court stressed that elections should be conducted in a manner subordinate to and not disruptive of the core academic objectives, with particular attention to minimizing interference with teaching, research, and examinations (!) (!) (!) .

  12. It was directed that university infrastructure should not be requisitioned for external elections in a manner that hampers academic activities, and alternative arrangements should be adopted for conducting elections to prevent academic disruption (!) (!) .

  13. The judgment reaffirmed that the primary goal of higher educational institutions is to promote academic excellence and discipline, and that democratic activities such as student elections should be structured to support, not hinder, this goal (!) (!) .

  14. Overall, the court emphasized that the conduct of student union elections is a constitutional and legal obligation, but must be balanced with the university’s academic priorities, and that future elections should be planned and conducted within a framework that safeguards educational integrity and student rights (!) (!) .

Please let me know if you need further elaboration or specific legal advice on this matter.


Table of Content
1. introduction to the case and context of student elections. (Para 1)
2. recognition of amicus curiae's assistance. (Para 2)
3. petitioners' grievances regarding delayed elections. (Para 3)
4. elections are essential for democratic participation. (Para 4 , 5 , 6 , 7 , 8)
5. counterarguments to influence of nep on elections. (Para 9 , 10 , 11 , 12 , 13)
6. fundamental right to elections supported by precedent. (Para 14 , 15 , 16 , 17 , 18 , 19 , 20)
7. opposition's arguments regarding petition's maintainability. (Para 21 , 22)
8. maintainability challenged based on locus standi. (Para 23 , 24 , 25 , 26 , 27 , 28)
9. respondent's rationale for not conducting elections. (Para 30 , 31 , 32 , 33 , 34 , 35 , 36 , 37 , 38)
10. balancing democracy within educational autonomy. (Para 40 , 41 , 42 , 43)
11. directions for future conduct of student elections. (Para 44 , 45 , 46 , 47 , 48 , 49 , 50 , 51 , 52 , 53 , 54 , 55 , 56 , 57 , 58 , 59 , 60 , 61 , 62 , 63 , 64 , 65)

JUDGMENT :

SAMEER JAIN, J.

1. In the present batch of writ petitions, the scope of controversy involved, albeit not limited to but is broadly and predominantly defined by the plea made seeking compliance of the lyngdoh committee recommendation (committee appointed by the Hon’ble Supreme Court in the case of University of Kerala v. Council, Principal Education, Kerala and ors., in Civil Appeal No. 887/2009) at point number 6.4.2 which purposes for yearly conduct of the student union elections; within six-eight weeks from the date of the commencement of the academic session. Consecutively, considering the fact that the writ petitions warrant adjudication on common questions of law and fact; with consent of the learned counsel appearing on behalf of the parties, SBCWP No. 11354/2025 titled as Jai Rao Vs. State Of Rajasthan And Ors., is being taken up as the lead case. It is cautiously clarified that any discrepancies in the present petitions, pertain purely to the factual narratives contained therein, and not vis-à-vis the questions of law to be determined by this Court; the instant judgment shall be applicable on all the petitions connected herein/henceforth on mutatis mutandis basis.

2. Before proceeding to the merits and demerits of the case at hand, this Court finds it appropriate to extend its sincere gratitude to the learned amicus curiae for his valuable assistance provided during the course of these proceedings. The submissions and insights offered by the learned amicus curiae have been of significant aid in clarifying complex legal and factual issues pertinent to the matter. Thence, the Court recognizes and appreciates the impartial and professional manner in which the learned amicus curiae has approached the matter, ensuring that the focus remained squarely on the advancement of justice. The Court is, therefore, grateful for the thoughtful and impartial perspectives offered, which have undeniably enhanced the quality of the proceedings.

ISSUES TO BE ADJUDICATED BY THIS COURT AND PRIMARY GRIEVANCE OF THE PETITIONERS AS NOTED IN THE LEAD PETITION:-

3. The present batch of writ petitions has been filed invoking the extraordinary jurisdiction of this Court under Article 226 of the Constitution of India . The petitioners have raised grievances regarding the respondents' failure to conduct the annual student elections for the academic session 2025-2026. The petitioners contend that the non-conduct of the elections is in violation of the directives set forth in the ratio of University of Kerala (supra), as well as the binding principles established by the Larger Bench of the Rajasthan High Court in the matter of Rajasthan High Court Advocates Association, Jodhpur & Anr. v. State of Rajasthan & Ors. (WRW No. 15/2005). It is contended that the respondents' actions are inconsistent with the judgment of the Larger Bench, which mandates the continuation of student elections in compliance with the recommendations of the Lyngdoh Committee. The petitioners seek adjudication on

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