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2026 Supreme(Del) 533

IN THE HIGH COURT OF DELHI AT NEW DELHI
DEVENDRA KUMAR UPADHYAYA, CJ, TEJAS KARIA, J.
Guru Gobind Singh Indraprashtha University - Appellant
Versus
Kumar Saurabh And Ors - Respondents
LPA 340 of 2024, CM APPL. 24481 of 2024
Decided On : 29-05-2026

Advocates Appeared:
For the Appellant :Ms. Anita Sahani, Advocate
For the Respondent: Dr. Sumant Bharadwaj, Ms. Mridula Ray Bharadwaj, Dr Vedant
Bharadwaj & Ms. Pooja Gupta, Advocates, Mr. Vikrant Nitesh Goyal, Mr. Yash
Basoya, Mr. Rakshit Tyagi, Mr. Kunal Dixit, Advocates

Admission to professional courses granted under a quota cannot be summarily cancelled without observing natural justice. When policies lack a restrictive definition of 'wards', the term broadly covers dependent family members, including siblings of unmarried personnel, to ensure equitable access and protection for the family of the deceased.

Headnote:(A) Public Law - Admission Policy - Defence quota - Interpretation of "wards" - Whether the expression "wards" excludes siblings of unmarried deceased personnel - In the absence of a restrictive definition, the term should encompass family members of the deceased - (Paras 36-41).

(B) Natural Justice - Administrative cancellation of professional course admission - Requirement for a meaningful opportunity of hearing - An admission granted after due diligence cannot be summarily cancelled based on an informal communication without adhering to the principles of fair procedure - (Paras 29-31).

(C) Administrative Law - Basis for administrative decisions - Decisions by public authorities must be reasoned and independent - An authority cannot reverse an earlier grant of admission merely by re-visiting original documents without evidence of suppression of material facts - (Paras 32-34).

Facts of the case:
The siblings of a deceased defence person were granted admission to an educational institution under a specialized quota based on submitted documents. The admission was subsequently cancelled by the institution based on an informal communication received from a government body suggesting ineligibility. The students challenged the legality of this cancellation.

Findings of Court:
The institution failed to provide a rational basis for the cancellation and violated the principles of natural justice by not granting a hearing. The court determined that the term "wards" in the reservation policy should be interpreted to include siblings in the case of unmarried personnel, consistent with broader policy objectives.

Issues: The main issues were whether the siblings qualified for the reserved quota and whether the cancellation of admission without an opportunity for a hearing was legally sustainable.

Ratio Decidendi: Admission granted after valid scrutiny cannot be revoked arbitrarily. The principles of natural justice mandate a hearing before taking adverse action, and the term "wards" is broad enough to include siblings of an unmarried deceased soldier in the absence of a restrictive statutory definition.

Result: Appeal dismissed.

Table of Content
1. establishing the factual background of the case, admission process, dispute origin, and procedural history. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18)
2. summary of rival contentions regarding interpretation of 'wards' and validity of admission. (Para 19 , 20 , 21)
3. the court evaluates the legitimacy of reliance on documentary evidence and initial verification processes. (Para 22 , 23 , 24 , 25 , 26 , 27 , 28)
4. admission cannot be cancelled without natural justice and valid reasons after initial verification. (Para 29 , 30 , 31 , 32 , 33 , 34)
5. broad interpretation of 'wards' includes siblings of unmarried defence personnel under policy framework. (Para 35 , 36 , 37 , 38 , 39 , 40 , 41)
6. final ruling upholding admission due to procedural fairness and interpretation of welfare policies. (Para 42 , 43 , 44 , 45 , 46)

JUDGMENT :

TEJAS KARIA, J.

1. The present Letters Patent Appeal has been filed challenging the judgment dated 18.03.2024 (“Impugned Judgment”) passed in W.P.(C) No. 12757/2023 (“Writ Petition”) titled as ‘Kumar Saurabh & Anr. v. Union of India & Ors.’ which was allowed.

FACTUAL MATRIX

2. The Appellant University was constituted under the Guru Gobind Singh Indraprastha University Act, 1998, enacted by the Legislative Assembly of the National Capital Territory of Delhi, and commenced functioning in the year 2007.

3. Respondent No. 3, the Ministry of Defence (“MoD”), issued Circular dated 30.11.2017 bearing F. No. 6(1)/2017/D(Res.II) (“Circular”), laying down the inter se priority for reservation in favour of wards of Armed Forces personnel by States and Union Territories for admission to medical, professional, and non-professional courses.

4. During the period 2021-2022, instructions were issued by the Kendriya Sainik Board in respect of the applicants seeking reserved Defence seats in medical and dental colleges as Government of India nominees under the MoD quota. The Joint Entrance Examination (Main), 2022 was conducted on 08.08.2022.

5. Respondent No. 1, Mr. Kumar Saurabh, and Respondent No. 2, Ms. Kumari Subhargi Priya, are the siblings of Mr. Kumar Shubham, a sailor in the Indian Navy, who died in harness on 16.09.2022 (“Deceased”).

6. In the year 2023, the Appellant issued its Admission Brochure for the Academic Session 2023-2024, setting out the reservation policy applicable to the wards of Defence personnel.

7. The Naval Pension Office, Mumbai (“Pension Office”), vide letter bearing No. NAVPEN/GB/IOFDRC/257519Y dated 10.02.2023, clarified the names of the family members of the Deceased available on record and further stated that the expression ‘Dependent’ would apply only to his next of kin.

8. The Rajya Sainik Board / Zila Sainik Board (“Board”) issued a Dependent Identity Card of Ex-Servicemen in the name of Respondent No. 1, recognising him as a ‘Dependent’ of the Deceased. Thereafter, on 13.04.2023, the Kendriya Sainik Board issued directions amending the guidelines governing the issuance of identity cards to dependents of ex-servicemen.

9. Respondent Nos. 1 and 2 appeared in NEET UG 2023, conducted on 07.05.2023. On the basis of their respective ranks, they were allocated to the Appellant for admission, pursuant to which they uploaded their profiles on the Appellant’s website. At that stage, the requisite documents, including the Relationship Certificates issued by the Pension Office, were also uploaded on the said portal.

10. The Pension Office issued a Relationship Certificate bearing No. IOFDRC/1355(B) dated 22.05.2023 (“Relationship Certificate”) on the request of Mr. Baidya Nath Singh, father of Respondent Nos. 1 and 2. The Relationship Certificate recommended Priority-III for the purpose of reservation in favour of the wards of Armed Forces personnel. On the same date, the Board issued Dependent Identity Cards of Ex-Servicemen in the names of Respondent Nos. 1 and 2, recognising them as dependents of the Deceased.

11. The Office of the Principal Con

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2026 Supreme(Del) 533

IN THE HIGH COURT OF DELHI AT NEW DELHIDEVENDRA KUMAR UPADHYAYA, CJ, TEJAS KARIA, J.Guru Gobind Singh Indraprashtha University - AppellantVersusKumar Saurabh And Ors - RespondentsLPA 340 of 2024, CM APPL. 24481 of 2024Decided On : 29-05-2026

Cases Referred (5)

IN THE HIGH COURT OF DELHI AT NEW DELHI
DEVENDRA KUMAR UPADHYAYA, CJ, TEJAS KARIA, J.
Guru Gobind Singh Indraprashtha University - Appellant
Versus
Kumar Saurabh And Ors - Respondents
LPA 340 of 2024, CM APPL. 24481 of 2024
Decided On : 29-05-2026