IIM Ahmedabad Lacks Authority to Expel First-Year DPM Students for Academic Shortfall Without Offering Remedial Measures: Gujarat High Court

The Gujarat High Court has delivered a significant verdict in the matter of Abhilasha Ashok Kumar vs. Indian Institute of Management & Ors. , setting aside the decision of the premier institution to expel doctoral students for academic shortcomings. The Court’s ruling emphasizes that educational institutions must strictly adhere to their own established policies before taking punitive measures that result in severe civil consequences for students.

Case Background

The petitioners, students enrolled in the Doctoral Programme in Management (DPM) at the Indian Institute of Management, Ahmedabad (IIM-A), challenged their expulsion from the program in June 2025. The institution had declared that the students failed to meet the criteria for progression from the first to the second year of their coursework.

Following a swift administrative decision, the petitioners were expelled without what they argued was proper due process. Despite appeals to the Director of the Institute, the decision was upheld. The students subsequently approached the High Court, contending that the expulsion violated the principles of natural justice, the institution's own manual, and the doctrine of legitimate expectation.

The Core Legal Dispute

The central question before Honourable Mr. Justice Nikhil S. Kariel was whether the IIM-A’s "Manual of Policies and Procedure" for the DPM actually permitted the summary expulsion of a student after the first year of coursework without exploring remedial avenues.

The petitioners argued that the program design, which is split into three thematic stages, explicitly requires the institution to offer review, rectification, and remedial measures before resorting to exclusion. Conversely, the Institute maintained that its Executive Committee holds final discretionary authority to ensure the maintenance of academic standards and that the term "stage" should be interpreted in its most practical sense.

The Court’s Reasoning

Analyzing the provisions of the IIM-A manual, the High Court focused on a contextual interpretation of the rules. Justice Kariel observed that the manual is structured to allow students multiple opportunities to rectify academic performance, including an additional year to clear shortfalls for students who fail to meet grade standards.

The Court held that the institution's rigid application of expulsion was at odds with the inclusive design of the programme. By strictly interpreting the manual as a cohesive document, the Court found that skipping remedial protocols rendered the expulsion orders "non-est and void ab initio."

Key Observations

The High Court’s ruling highlighted critical lapses in procedure:

• "The underlying objective being that if a student is meritorious enough to get selected for course in question then adequate opportunity should be given to the said student to complete the course and the idea very glaringly not being to remove a student from the programme at the very first opportunity."
• "No part of the Manual envisages that a student could be directed to leave the programme upon the student not clearing the first year of ‘Coursework’."
• "It would thus appear that the manual does not envisage requirement of leaving the programme upon non completion of the first and the second year at the first instance itself."

Implications and Conclusion

The High Court has quashed the orders dated June 7, 2025, and June 18, 2025, effectively allowing the students to remain in the programme. The Court has also provided a four-week stay on the order to allow the Institute time to calibrate its next steps, while ensuring the petitioners are protected from eviction from their university accommodations during this period.

This decision serves as a stern reminder to academic bodies that they are bound by their own internal regulations. In matters involving significant academic and professional consequences, adherence to prescribed procedural fairness is not merely a courtesy—it is a legal necessity. Any institution operating under a formal manual must ensure that its actions are demonstrably aligned with the text and purpose of those governing documents.