An institution is required to comply with principles of natural justice and issue a show-cause notice before imposing disciplinary penalties for examination malpractice, and judicial review will not intervene in administrative proceedings if the matter has attained a stage where the appeal has become infructuous.

JUDGMENT :

Muralee Krishna S., J.

These Writ appeals are filed by the appellant under Section 5(i) of the Kerala High Court Act, challenging the judgments dated 14.01.2026 in W.P.(C) No.45538 of 2025 and 27.02.2026 in W.P.(C) No.6246 of 2026, respectively, passed by the learned Single Judge in those writ petitions filed by the appellant. For convenience of reference, the parties and documents are referred to as in W.A.No.624 of 2026.

2. The appellant is a student of the Bachelor of Pharmacy (B.Pharm) Degree course at Mar Dioscorus College of Pharmacy, Thiruvananthapuram, affiliated to the Kerala University of Health Sciences (‘KUHS’ for short). When the appellant was attending the first examination of the seventh semester, B.Pharm Degree supplementary examinations for the subject Instrumental Methods of Analysis, conducted on 25.08.2025, an eraser containing handwritten markings was seized from him. Pursuant to the surrender of that objectionable material and giving a written statement of apology by the appellant, he was permitted to attend the remaining examinations in that semester. Thereafter, the appellant was called for a hearing before the 172^nd meeting of the Malpractices and Lapses Enquiry Committee (M&LEC) scheduled on 27.09.2025. Subsequently, by Ext.P7 order dated 30.10.2025, the appellant was disqualified from appearing in the seventh semester B.Pharm examination for the next chance and his appearance in the entire seventh semester supplementary examination of August 2025 was cancelled. The punishment imposed on the appellant was stated to be under Chapter XII, Clause I(A), 1(1) of the KUHS Examination Manual. Aggrieved by Ext.P7 order, the appellant approached this Court by filing W.P.(C)No.45538 of 2025 under Article 226 of the Constitution of India, seeking the following reliefs:

“a. Issue a Writ of Certiorari or any other appropriate Writ, order or direction, calling for the records leading to the issuance of the Impugned Order U.O.No: 795/2025/exam/KUHS dated 30.10.2025 (Exhibit P7) and to quash the penalty of disqualification and debarment from appearing in the subsequent chance for the Seventh Semester B.Pharm Degree Examinations as being grossly disproportionate;

b. Issue a Writ of Declaration or any other appropriate Writ, order or direction, declaring the relevant rule/proviso of the KUHS Manual/Regulations that mandates or permits a blanket cancellation in the whole examination and debarment from the next chance, for minor/technical possession of crib notes as arbitrary and violative of Article 14 of the Constitution of India;

c. Issue a Writ of Mandamus or any other appropriate Writ, order or direction, commanding the Respondent University to reduce the penalty to a proportional one, such as the cancellation of the specific paper (Instrumental Methods of Analysis) only.”

3. On 17.12.2025, when W.P.(C)No.45538 of 2025 came up for consideration, the learned Single Judge, by an interim order, directed the 1^st respondent, KUHS, to permit the appellant to remit the fees and appear for the seventh semester supplementary examinations in December 2025. It was made clear in that order that the permission granted was provisional and would be subject to the outcome of the writ petition. The results of the examination were not to be published for the time being.

4. In W.P.(C)No.45538 of 2025 on behalf of the respondents, a statement dated 11.12.2025 was filed opposing the reliefs sought for. Thereafter, the appellant produced Ext.P9 document along with I.A.No.1 of 2026. To the statement filed on behalf of the respondents, the appellant filed a reply affidavit dated 07.01.2026.

5. After hearing both sides, the l