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2026 Supreme(Online)(Mad) 48230

IN THE HIGH COURT OF JUDICATURE AT MADRAS
G. R. Swaminathan, J
Karalmarx – Appellant
Versus
Registrar, Tamil Nadu Dr.Ambedkar Law University – Respondent
W.P.No.21669 of 2026



Advocates:
For the Appellants/Petitioners: A. Rahul
For the Respondents: Hasan Faizal, Nallathambi

A student who exceeds the maximum permissible time limit, including extended years for clearing backlogs as per UGC guidelines and university resolutions, ceases to be a student and cannot be granted a mandamus to appear for further examinations.

Headnote:The petitioner filed a writ petition seeking a Mandamus to permit them to appear for BA LLB supplementary examinations beyond the stipulated extended period. The court examined the UGC guidelines on the 'Uniform Span Period' for degree completion (N+2 years for new admissions) and the resolution adopted by the university allowing three additional years for currently ongoing students to clear backlogs. The court observed that the petitioner, admitted in the 2017-18 academic year, failed to clear the degree within the mandated extended period. The core issue was whether a student who has exhausted the permissible extended period for completing a degree course can be granted permission to appear for supplementary examinations. The court determined that as the guidelines and university resolutions were not challenged and remain in force, it is bound to apply them, precluding the issuance of any mandamus contrary to such established norms. The writ petition stands dismissed.

Table of Content
1. overview of the petition seeking permission to write examinations after the completion of the regular course duration. (Para 1 , 2)
2. arguments based on parity and existing stays of similar interim orders. (Para 4)
3. application of ugc guidelines and university resolutions regarding the maximum time span for degree completion. (Para 5 , 6 , 7)

ORDER

Heard both sides.

2.The writ petitioner joined the five year integrated BA LLB degree course in the third respondent Central Law College during the academic year 2017-18. He was unable to successfully complete the course at the end of the five year period. He had to write supplementary examinations for two subjects. The respondent university published the current examination schedule commencing from 08.05.2026. He now wants this Court to direct the authorities to permit him to right the supplementary examinations to be held this month. Hence, this writ petition came to be filed.

3.The learned counsel for the petitioner relies on the interim order dated

29.04.2026, passed in WP (MD) Nos.13253 to 13258 of 2026, wherein, a learned Judge of this Court had granted interim relief to a similar candidate.

4. The learned Standing Counsel points out that this order has been stayed by the Hon’ble Division Bench in WA(MD) Nos.644 to 646 of 2026, dated

06.05.2026.

5. I am not in a position to grant relief to the petitioner. It is not in dispute that the UGC had issued guidelines on determination of Uniform Span Period within which a student may be allowed to qualify for a degree. The guidelines are as follows:

“ 1. A student who for whatever reasons is not able to complete the programme within the normal period or the minimum duration prescribed for the programme, may be allowed two years period between the normal period to clear the backlog to be qualified for the degree. The general formula, therefore it is as follows, Time span = N+2 years for the completion of course.

Where N stands for nomal or minimum duration prescribed for the completion of the programme.

The N+2 rules adopted by the Syndicate and Academic Senate shall be prospective and will be applicable for all the students of the University admitted from the Academic year

2019-20 onwards uniformly.

For example, if a student gets admitted in the year 2019-

20 of 3 year L.L.B. Degree course, he / she should complete the course in the year 2022, ie., the normal period prescribed for the course. If he / she has any backlog, they should complete it within the year May 2024 ie., extra 2 years to complete the backlog.

2. The students who are currently studying in various programmes will be given three additional chances after completion of their regular period of study to become eligible for award of the Degree from the time of joining in the programme. In case, any student fails to complete the respective programme within the extended period of time such candidates cases to be a student of the University.

It is resolved that three additional chances means three years, after completion of stipulated years of regular period of a course. This is applicable to all courses of the University including courses offered in the affiliated law colleges and except Ph.D programme which is regulated by its own regulations within the extended period of time such candidates ceases to be a student of the University.

For example, if a student gets admitted in the year 2017-

18 of 5 year B.A.L.L.B. Degree course, he / she should complete the course in the year May 2022, ie., the normal period prescribed for the course. If he / she has any backlog, they should complete it within the year 2025 ie., extra 3 years to complete the backlog.”

6. These guidelines were adopted by the Syndicate in its 158th meeting held on 31.12.2018 and 160th meeting held on 27.03.2019. The resolution reads as follows:

1. The N+2 rules shall be prospective and will be applicable for the students of all courses admitted from the academic year 2019-20 onwards uniformly.

2. The studen

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