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2026 Supreme(Telangana) 101

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Surepalli Nanda, J.
Arshiya Fathima - Petitioner
Versus
Meghana Institute of Dental Sciences Represented by its Registrar and others - Respondents
Writ Petition No.1395 of 2026
Decided On : 16-01-2026

Advocates:
Advocate Appeared:
For the Appellant : Syeda Arshiya Mahjabeen

The court upheld that educational regulations mandating completion within nine years are binding and cannot be overridden by claims of hardship or health, emphasizing adherence to the rule of law.

Headnote:(A) Constitution of India - Articles 14, 19, and 21 - Writ of Mandamus - Petition seeking to direct the University to allow the petitioner to appear for final year BDS examinations and complete internship despite not meeting time regulations. (Para 2-3)

(B) Education Regulations - Revised BDS Course (7th Amendment) Regulations, 2015 - Regulations mandate completion of the BDS Course within nine years, including compulsory internship; failure to do so results in discharge from the course. (Para 7)

(C) Legal Precedents - Supreme Court ruling emphasizes that courts cannot compel compliance contrary to established regulations. (Para 10)

Facts of the case:
The petitioner, after an emergency medical procedure, failed three subjects and was denied a chance to appear in subsequent examinations despite multiple requests. (Paras 4 and 10)

Findings of Court:
The court upheld the mandatory regulations for course completion, emphasizing no discretion can be applied to extend these limits. (Para 8)

Issues: The core issue involved whether exceptional circumstances justify an extension beyond the permissible length for course completion. (Para 8)

Ratio Decidendi: Regulations are binding, and courts must refrain from issuing mandamus against statutory provisions. (Para 10)

Result: Writ Petition dismissed, with no costs. (Para 11)

Table of Content
1. petitioner's request after medical emergency. (Para 2 , 3)
2. petitioner’s prior related cases and court orders. (Para 4)
3. arguments regarding equity and strict rules. (Para 5 , 6)
4. court’s stance on regulations and limits. (Para 7 , 8)
5. mandamus cannot contravene established regulations. (Para 9 , 10)
6. writ petition dismissed without costs. (Para 11)

ORDER :

Surepalli Nanda, J.

Heard Ms. Syeda Arshiya Mahjabeen, learned counsel appearing on behalf of the petitioner and Sri T.Sharath, learned Standing Counsel for Kaloji Narayanrao University of Health Sciences appearing on behalf of the respondent N.2.

2. The petitioner approached the Court seeking prayer as under:

“…Issue a Writ of Mandamus or any other appropriate Writ, Order or Direction directing the Respondents to permit the Petitioner, Mrs. Arshiya Fathima, to appear for the remaining Final Year BDS examinations commencing from 17.01.2026 for the three pending subjects, in accordance with law.

Direct the Respondents, upon completion of the theory examinations, to provide the Petitioner with an expedited and time-bound schedule for completion of her Compulsory Rotatory Internship, strictly within the permissible period prescribed under the Dental Council of India Regulations.”

3. The case of the petitioner in brief as per the averments made in the affidavit filed by the petitioner in support of the present writ petition is as under:

i) The petitioner was a final year BDS student in respondent No.1 College. The respondent No.2 issued notification for the final year BDS examinations scheduled in January, 2025.

ii) During the course of examinations in the year 2025, the petitioner underwent an emergency Caesarean Section and delivered a male child and hence, the petitioner could not secure passing marks in three subjects i.e., Orthodontics, Prosthodontics, and Conservative Dentistry & Endodontics.

iii) Though the petitioner submitted several representations to the respondent authorities requesting to permit the petitioner to appear for the January-2026 examinations, the respondents refused to permit the petitioner. Aggrieved by the same, the petitioner approached this Court by filing the present writ petition.

4. PERUSED THE RECORD:

A) On an earlier occasion, the petitioner approached this Court by filing W.P.No.34643 of 2024 seeking prayer as under:

“…….to issue a Writ, Order, or Direction, more particularly one in the nature of a Writ of Mandamus, declaring the actions of Respondent No. 1(MIDS) and the inaction of Respondent No.2 (KNRUHS) in barring the Petitioner from appearing for final year examinations and completing her internship as illegal, arbitrary and violative of Articles 14, 19 and 21 of the Constitution of India. It is further prayed that this Honorable Court direct Respondent Nos. 1 and 2 to permit the Petitioner to appear for the January, 2025 final-year examinations and complete her Compulsory Rotatory Internship as per DCI regulations along with suitable adjustments to the internship schedule to ensure completion before the expiry of the nine year window. The Petitioner also prays for an investigation into administrative and financial malpractices by Respondent No.1 and directives to Respondent No. 3(DCI) to enforce compliance with its regulations across affiliated institutions. By way of interim relief the Petitioner prays for immediate permission to appear for the January, 2025 examinations and expedited scheduling of internship postings. The Petitioner humbly seeks any other order or directions that this Honorable Court may deem fit and proper in the interest of justice.”

B) The relevant portion of the Division Bench order of this Court dated 20.12.2024 passed in W.P.No.34643 of 2024 filed by the petitioner herein on an earlier occasion, is extracted hereunder:

“8. The petitioner was admitted to BDS Course in the academic year 2016-17. She passed the First Year BDS examination in November, 2017. Thereafter, she appeared in the Second Year BDS exa

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