IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Kuldeep Tiwari
Gunjan Jaiswal -Petitioner
Versus
The Vice Chancellor, Panjab University And Others - Respondents
CWP-36541-2025
Decided On : 13-01-2026
JUDGMENT :
KULDEEP TIWARI, J.
1. Through instituting the present writ petition, the petitioner seeks twofold relief: first, quashing of the order dated 28.10.2025 (Annexure P-4), whereby the petitioner’s request for declaration of her 3rd and 4th semester M.Sc. (Microbial Biotechnology) examination results was rejected; and second, issuance of a direction to the respondent(s) to declare the petitioner’s results for the said semesters.
2. The undisputed facts of the present case are that the petitioner was enrolled as a student of M.Sc. (Microbial Biotechnology) for the academic session 2016-2018 at the respondent No.4- College. She appeared in the 1st semester examinations in December 2016 and the 2nd semester examinations in May 2017. Thereafter, owing to personal reasons, she discontinued the course and did not appear in the 3rd semester examinations conducted in December 2017. After a hiatus of approximately three years, the petitioner approached the respondent No.4-College seeking to resume her M.Sc. course. She was permitted to take re-admission in the 3rd semester, pursuant to which she deposited the requisite fee and was issued a Roll Number/Admit Card. Accordingly, she appeared in the 3rd semester examinations held in February 2021. However, her result was withheld by the University. Subsequently, the petitioner also appeared in the 4th semester examinations after depositing the requisite fee and being issued a Roll Number/Admit Card, but the result thereof was likewise withheld. It is noteworthy that the petitioner remained silent for nearly three years thereafter and, only on 29.09.2025, issued a legal notice seeking declaration of her results. In response, the University passed the impugned order declaring the petitioner ineligible and cancelling her candidature in terms of Regulation 11 of the Panjab University Calendar, Volume-II, 2007 (hereinafter referred to as the “University Calendar”), which mandates that a student cannot spend more than a maximum period of three years in M.Sc. classes.
3. Learned counsel for the petitioner contends that once the petitioner was granted re-admission to the 3rd and 4th semesters, issued Roll Numbers/Admit Cards, and permitted to appear in the examinations, the University is estopped from subsequently declaring her ineligible and refusing to declare her results by cancelling her candidature. She also places reliance upon the judgment of the Hon’ble Supreme Court in “Sanatan Gauda v. Berhampur University and Others”, 1990(2) SCR 273, to argue that the principle of estoppel applies, and that the University cannot withhold or refuse to publish the results of a student who was admitted, allowed to pursue the course, and permitted to appear in the examinations.
4. Per contra, learned counsel appearing for the respondent Nos.1 to 3-University submits that there is a clear violation of Regulation 11 of the University Calendar, inasmuch as the petitioner admittedly took a break of nearly three years after appearing in the 2nd semester examinations. Consequently, the University was fully justified in withholding the results of the 3rd and 4th semester examinations on the ground of ineligibility. It is further contended that Regulation 5.2 of the University Calendar specifically empowers the Controller of Examinations to cancel the candidature of a candidate who is found ineligible even after issuance of a Roll Number or appearance in the examination
5. This Court specifically queried learned counsel for the petitioner as to the statutory provision under which the petitioner could be deemed eligible to continue her M.Sc. course after an undisputed break of approximately three years. Learned counsel was unable to point out any provision in the University Calendar permitting continuation of the course beyond the prescribed maximum period of three years.
6. The reliance placed by learned counsel for the petitioner on the judgment in Sanatan Gauda’s case (supra) is also misplaced, as the factual ma
Educational institutions cannot withhold results based on procedural errors after allowing students to take examinations, emphasizing the need for adherence to statutory obligations.
The court emphasized the importance of considering a student's legitimate expectations and the impact of University rules on academic progression, especially in the context of the Covid-19 pandemic.
The court emphasized that the proposition that the University is precluded from holding back a result of a candidate if allowed to sit and participate in the examination is not of universal applicati....
Court ruled that educational institutions must act fairly and acknowledge students' legitimate expectations, particularly after allowing them to participate in examinations despite procedural discrep....
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