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2026 Supreme(Online)(Mad) 90906

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Krishnan Ramasamy, J
M.M. Nalina Sudhanii – Appellant
Versus
Registrar Tamil Nadu Dr. MGR Medical University – Respondent
WP No. 36353 of 2026|WMP NO. 40690 OF 2026



Advocates:
For the Appellants/Petitioners: M.P. Rajavelayutham, S. Doraisamy
For the Respondents: Hari Radhakrishnan, G. Ramdas

Admissions made pursuant to interim court orders should not be disturbed arbitrarily, and students should not be penalized by withholding results while the underlying eligibility, such as a community certificate, is under judicial adjudication.

Headnote:(A) Education Law - MBBS Course - Withholding of Results - Non-production of community certificate - Where admission is granted pursuant to an interim order of the Court, the student's progress and results should not be arbitrarily disturbed or withheld for the same reason that was the subject of the interim relief. (Para 6)

(B) Administrative Law - Community Certificate - Pending Adjudication - A student permitted to pursue a course under a specific category by court order should be allowed to continue until the final adjudication of the community status dispute. (Para 6)

Issues: Whether the university can withhold the examination results of a student admitted under an interim court order due to the non-production of a community certificate.

Prayer: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of writ of mandamus directing the respondents to permit the petitioner (Reg. No. 520025115052) to pursue the MBBS course without any hindrance and to appear for the yearly examinations and publish the resultsthereafter.

Order

This Writ Petition has been filed for a direction to the respondents to permit the petitioner to pursue his MBBS course without any hindrance, and to appear for the yearly examinations, and for a subsequent publication of his results.

2. The learned counsel appearing for the petitioner submitted that the petitioner belongs to the Kondareddis community, which is classified as a Scheduled Tribe (ST) community. The petitioner's parents obtained their community certificates in 1978. Crucially, the communal status of the petitioner’s maternal uncle was verified and confirmed by the State Level Scrutiny Committee on 3 July 2023. While so, the petitioner’s father submitted an application on 09.10.2020 requesting the issuance of a community certificate to the petitioner, followed by an online application on 28.10.2022. However, the Revenue Divisional Officer (RDO), without conducting any enquiry, rejected the petitioner’s claim. Aggrieved by the rejection order, the petitioner preferred W.P. No. 865 of 2025, which is currently pending disposal.

3. In the meantime, the petitioner appeared for the NEET examination and scored 427 out of 720 marks. Due to the delay in the issuance of his community certificate, he was unable to attend the regular counselling session. Consequently, the petitioner preferred W.P. No. 23269 of 2025 seeking permission to participate in the MBBS counselling. This Court, by an interim order dated 30.06.2025, permitted the petitioner to participate in the 2025–2026 MBBS/BDS counselling under the Scheduled Tribes (ST) category. Accordingly, the petitioner participated and was selected by the third respondent college. The petitioner subsequently appeared for the first-year examinations conducted in July 2026. However, while the results of other candidates were published, the petitioner’s results were withheld due to the non- production of his community certificate, preventing him from continuing his course. Aggrieved by the same, the petitioner has preferred the present writ petition.

4. The learned counsel appearing for the respondents submitted that any order passed by this Court will be duly implemented.

5. Heard both sides and perused the materials available on record.

6. Such being the case, it is well-settled that when an admission is made pursuant to the interim orders of this Court, the same should not be disturbed arbitrarily. In the present case, the petitioner was permitted to participate in the counselling and pursue his M.B.B.S. course under the ST category by virtue of the directions issued by the Hon’ble Division Bench of this Court in W.P. No. 23269 of 2025. It appears that while the first-year examination results have been published generally, the result of the petitioner alone has been withheld for non- production of his community certificate. Prima facie, it is evident that the petitioner’s parents and his maternal uncle possess Scheduled Tribe community certificates, and the maternal uncle’s certificate has notably been verified and confirmed by the State Level Scrutiny Committee. Therefore, the third respondent University/College is directed to publish the results of the petitioner's first-year examinations and permit her to continue pursuing the M.B.B.S. course in the subsequent years until its completion. Furthermore, the petitioner is directed to produce his community certificate before the authorities concerned immediately upon its issuance, which shall remain subject to the final adjudication and outcome of the pending writ petition in W.P. No. 865 of 2025.

7. Accordingly, this Writ Petition is disposed of with the above observations. No costs. Consequently, the connecte

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