Rajasthan High Court Dismisses Petitions Seeking Student Union Elections, Issues Prospective Guidelines for Balance Between Democracy and Academics

Jaipur, Rajasthan – In a significant ruling, the Rajasthan High Court at Jaipur dismissed a batch of writ petitions seeking directions for the conduct of student union elections in the University of Rajasthan for the 2025-26 academic session. While rejecting the petitions on grounds of locus standi and prematurity, the court, presided over by Justice Sameer Jain, issued comprehensive prospective directions to ensure student participation in democratic processes without disrupting academic schedules. The judgment underscores the balance between fostering student democracy and maintaining institutional autonomy under the National Education Policy (NEP) 2020.

Case Background and Parties Involved

The petitions, led by S.B. Civil Writ Petition No. 11354/2025 titled Jai Rao vs. State of Rajasthan and Ors. , were filed under Article 226 of the Constitution of India by a group of students. The petitioners, including Jai Rao and others, challenged the respondents' failure to hold annual student union elections for the 2025-26 session, alleging violations of fundamental rights and judicial precedents.

The respondents included the State of Rajasthan and the University of Rajasthan. The court appointed an amicus curiae to assist in the proceedings, treating the petitions as interconnected due to common questions of law and fact. The core grievance revolved around the non-compliance with the Lyngdoh Committee recommendations, approved by the Supreme Court in University of Kerala v. Council of Principals' Colleges, Kerala (2004), which mandate yearly elections within 6-8 weeks of the academic session's start.

The legal question at hand: Whether student union elections must be held annually in Rajasthan's educational institutions, the timing, mode, and regulatory authority, amid arguments over their status as a fundamental right under Articles 19(1)(a) and 19(1)(c) of the Constitution.

Key Arguments by Petitioners and Amicus Curiae

The petitioners, supported by the amicus curiae, argued that student union elections are integral to holistic education and a fundamental right under Article 19(1)(a) (freedom of speech and expression) and Article 19(1)(c) (right to form associations). They relied on the Supreme Court's University of Kerala judgment, which upheld the Lyngdoh Committee's binding guidelines, and the 2011 order in the same case affirming elections as part of democratic training.

The amicus curiae emphasized that elections instill constitutional values and leadership, citing historical precedents like Bharat Bhushan Pareek vs. University of Rajasthan (1989) for annual elections. They dismissed claims of academic disruption, noting that university infrastructure is routinely used for general elections without halting academics. The NEP 2020 was not seen as prohibiting elections, and parity with other states was highlighted. Fees collected for elections could not be diverted, and even a small number of petitioners sufficed to invoke rights.

Petitioners further invoked the Rajasthan High Court's Larger Bench decision in Rajasthan High Court Advocates Association v. State of Rajasthan (WRW No. 15/2005), which mandated compliance with Lyngdoh guidelines, overruling prior contradictory rulings.

Respondents' Counter-Arguments

The respondents contested the petitions' maintainability, arguing no fundamental or statutory right was infringed. They claimed the right to vote in student elections is statutory, not fundamental, citing University of Delhi v. Anand Vardhan Chandel (2000) and N.P. Ponnuswami v. Returning Officer (1952). The 2011 Supreme Court order in University of Kerala was interim and lapsed with the appeal's dismissal in 2016.

On locus standi, only five petitioners represented thousands of students without authorization, ignoring internal remedies like approaching the Dean of Student Welfare (DSW) under the Rajasthan University Students' Union (RUSU) Constitution, 2010. The petitions were premature, lacking any prior grievance or adverse decision.

Merits-wise, the respondents justified non-conduct due to NEP 2020's semester system requiring 180 teaching days annually, backlogged exams, and local body elections. The RUSU framework lacks statutory force under the Rajasthan University Act , 1946, allowing reasonable restrictions for public order and academics. Political interference concerns were raised, aligning with Lyngdoh's intent to curb it.

Court's Analysis and Reliance on Precedents

Justice Jain's 65-paragraph judgment carefully balanced student aspirations with academic primacy. While acknowledging student elections' role in democratic nurturing, the court dismissed the petitions on preliminary grounds:

• Lack of Locus Standi : A "handful of students" without representative capacity could not espouse the cause of lakhs across 28 state universities, 53 private ones, and 596 colleges. Public interest litigation norms were not met.

• Prematurity : No exhaustion of internal remedies (e.g., DSW) or prior representation; writs cannot address hypothetical issues or pre-decisional stages.

The court distinguished quashing from mandamus, noting writ jurisdiction is discretionary and equitable. It referenced Vineet Narain v. Union of India (1998) for issuing guidelines in public interest despite declining relief.

On merits, though not adjudicated, the judgment critiqued selective infrastructure use for general elections versus student ones as arbitrary under Article 14. It clarified Lyngdoh guidelines as binding interim measures but emphasized academic continuity.

Pivotal excerpt: "Student democracy and academic autonomy are not adversaries; when guided by discipline, transparency, and reason, both coexist to strengthen the very foundation of education." (Para 45)

Final Decision and Prospective Directions

The petitions were dismissed without costs, clarifying no mandate for 2025-26 elections due to the academic year's advanced stage and ongoing processes. However, prospective directions were issued:

To Students/Petitioners

• Raise grievances first with DSW or Election Board.
• A meeting on January 19, 2026, at 11:00 AM, involving university and college representatives to deliberate and decide on elections within 15 days, notified prospectively.

To Universities/State

• Maintain Election Board for hearings and fee accountability.
• Issue election calendars in March annually, adhering strictly unless justified.
• Enforce RUSU Guidelines 2017, curbing external political interference (e.g., ABVP, NSUI).

On Academic Primacy

• Elections must not disrupt teaching, exams, or research; impose necessary restrictions.

To Election Commission/Civil Authorities

• Minimize requisitioning university infrastructure for general elections; use alternatives to preserve 180 teaching days under NEP 2020.
• Factor academic calendars into election planning.

Implications of the Ruling

This decision reinforces procedural rigor in writ petitions while promoting structured student democracy. It prevents recurring litigation by mandating internal resolutions and transparent decisions, benefiting Rajasthan's 26,500+ University of Rajasthan students and beyond. Copies were directed to the Election Commission, Chief Electoral Officer, and Vice-Chancellor for compliance.

The judgment, applicable mutatis mutandis to connected petitions (Nos. 11789/2025, 11800/2025, 13904/2025, 14689/2025), leaves room for future policy shifts but prioritizes education's core mandate.