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2025 Supreme(Kar) 2113

IN THE HIGH COURT OF KARNATAKA AT BENGALURU
S.R.KRISHNA KUMAR, J.
 
Chandan M., S/o. Mahesh M. – Appellant
Versus
The State Of Karnataka, Rep By Its Principal Secretary Education Department –Respondent
Writ Petition No. 36817 Of 2025 (EDN-RES)
Decided On : 05-12-2025
 

Advocates Appeared:
For the Appellant : Sri. Umashankar B.M, Adv.
For the Respondent: Sri. Manjunath K., HCGP., Sri. K. Girish Kumar, Adv.

I.T.I. qualifications are to be considered equivalent to Pre-University requirements for admission to a Three-Year LL.B. Degree Course, promoting equitable access to education.

Headnote:(A) Bar Council of India Rules - Rule 2(vi), Rule 2(viii), Rule 5 - Writ of Mandamus for eligibility certificate for LL.B. admission - Court found I.T.I. qualification is equivalent to Pre-University standard and directed issuance of eligibility certificate. (Paras 4, 8, 20)

(B) Precedents - Court’s rulings in prior cases establish that qualifications should not exclude candidates based on open university systems alone; precedent supports broader interpretation of eligibility criteria. (Paras 2, 6)

Facts of the case:
The petitioner sought admission to the Three-Year LL.B. Degree Course despite the denial of eligibility based on prior qualifications through I.T.I. despite fulfilling degree requirements.

Findings of Court:
The petition is allowed, and the University is directed to consider I.T.I. as equivalent to Pre-University and issue eligibility for LL.B. (Para 19).

Issues: The main issue was whether I.T.I. training could be considered equivalent to Pre-University qualifications as required for LL.B. admission.

Ratio Decidendi: The court ruled that existing Bar Council Rules allow for broader interpretations of academic eligibility and emphasized the need for equity in educational admissions (paragraphs 5, 12).

Result: Writ petition allowed.

Table of Content
1. petition seeks writ of mandamus for eligibility certification. (Para 1 , 2)
2. previous cases establish similar eligibility issues. (Para 3 , 4 , 5 , 6)
3. regulations and rules governing eligibility for ll.b. (Para 7)

ORDER :

S. R. KRISHNA KUMAR, J.

1. In this petition, petitioner seeks the following reliefs:

“(i) To issue a WRIT OF MANDAMUS, in the nature of Order or direction, directing the Respondent No.2 to issue an eligibility certificate to the petitioner as per the Annexure-A and thereby permit the Petitioner herein to participate in the examination to be held in January 2026 in respect of subject of 1st Semester in Three Year LL.B. Degree Course in Law, in the interest of justice and equity.

(ii) To grant such other relief as this Hon’ble Court may be pleased to deem fit to grant in the circumstances of the case to meet the ends of justice and equity.”

2. Heard the learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3. A perusal of the material on record would indicate that the issue in controversy involved in the present petition is directly and squarely covered by the judgments of this Court in the cases of Sri.Naveenkumar K.V., Vs. The Karnataka State Law University and Ors – W.P.No.26757/2024 dated 01.10.2024 and Rakesh Shetty Vs. The State of Karnataka and Ors. - W.P.No.31737/2024 dated 09.12.2024.

4. In Sri.Naveenkumar K.V.’s case, (supra), this Court has held as under:

In this petition, petitioner seeks the following relief:

i) Issue a Writ in the nature of certiorari to quash the impugned endorsement bearing Application ref No.LW002S240001257 dated 21.09.2024 issued by the 1st respondent vide Annexure-R and consequently, direct the respondent No.1 to issue eligibility certificate in favour of petitioner by considering his qualification for admission to Three Year Law Degree Course in any of the Recognized colleges of the 1st respondent, in the interest of justice and equity.

ii) Grant such other reliefs as may be deems to be fit to the facts and circumstances of the case, in the interest of justice and equity."

2. Heard the learned Counsel for the petitioner and learned Counsel for respondent No.1 and perused the material on record.

3. A perusal of the material on record would indicate that issue in controversy involved in the present petition is directly and squarely covered by the judgments of this Court in the cases of Mr.Abubakar Vs.Karnataka State Law University and others- W.P.No.200642/2021 dated 08.12.2021 and Sri N.Dinesh Vs. The Karnataka State Law University -W.P.No.15723 of 2023 dated 22.08.2023.

4. In Abubakar's case (supra), this Court has held as under:

"The petitioner has completed his SSLC in the academic year 2009-10 from Urdu High School, Jewargi, District Kalaburagi. Thereafter, he has completed I.T.I (Electrician), a two years course from Shri Noorandeshwar I.T.I, Jewargi in the year 2012. Thereafter, he has passed three years B.A. Degree in the year 2020 from Gulbarga University, Kalaburagi. Thereafter, he has approached respondent No.2 for admission to three years LL.B course. The same has been rejected by respondent No.2 on the ground that the petitioner has not passed 10+2+3 as contemplated under the law. Aggrieved by the same, the petitioner has preferred this writ petition.

2. The contention of the respondents is that the petitioner ought to have passed Pre-university after passing 10th standard and thereafter should have completed his Degree and then only he would be eligible for admission to LL.B. But, the petitioner has completed a I.T.I course for two years and hence he is not being considered for admission to LL.B.

3. Rule 2(vi) of the Rules of Legal Education framed by the Bar Council of India (hereinafter referred to as ‘the Rules’) defines ‘Bachelor degree in law’ as under:

“2(vi) “Bachelor degree in law” means and includes a degree in law conferred by the University recognized by the Bar Council of India for the pur

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