Concerned About Future of Legal Profession: Bombay HC Pulls Up Law Student For Scurrilous Conduct In Review Plea

The Bombay High Court has dismissed a review application filed by an LL.M. student of Maharashtra National Law University (MNLU), Chhatrapati Sambhajinagar, who sought reconsideration of an earlier order refusing her permission to appear for semester examinations due to shortage of attendance.

Holding that review jurisdiction cannot be used as an appellate remedy, the Court observed that the student had merely attempted to re-argue issues already decided in the writ proceedings.

A Division Bench of Justice Vibha Kankanwadi and Justice Ajit B. Kadethankar was hearing a review application filed by Ankita Jagannath Sonawale, who appeared in person. The respondents were represented by Advocate S.K. Kadam. The student had earlier challenged the University's decision barring her from appearing in the second semester LL.M. examination for failing to meet the mandatory attendance requirement prescribed under the Maharashtra National Law University Regulations, 2020. Her writ petition was dismissed on April 30, 2026.

In the review application, the student sought a wide range of reliefs, including reconsideration of the earlier judgment, production of attendance records, CCTV footage of grievance committee proceedings, and a direction to conduct a special examination for her. She also alleged irregularities in the computation of attendance, discrimination in granting attendance benefits to other students, and failure by the University to consider her medical circumstances.

The Court, however, found no merit in the contentions. Addressing the central issue of attendance, the Bench noted that the University's regulations mandated 75 percent attendance and that a policy permitting relaxation for students who achieved at least 67 percent attendance with valid medical justification had been adopted by the institution through a committee resolution approved by the Vice-Chancellor. The judges observed that the applicant did not even claim to have attained the 67 percent threshold.

The Bench further noted that even according to the student's own calculations, her attendance could at best reach 51.12 percent, far below both the prescribed requirement and the relaxation benchmark. Rejecting allegations of errors in attendance computation, the Court held that no error apparent on the face of the record had been demonstrated. It observed that the applicant's understanding of what constitutes an "error apparent on the face of the record" was fundamentally misconceived.

The Court was also critical of allegations levelled against the University, faculty members and a fellow student. It described several assertions in the review application as "absolutely reckless and irresponsible" and noted that they were unsupported by evidence. The judges took particular exception to the applicant's attempt to question the attendance record of a batchmate and directed the Registry to mask the student's name in court records to protect his privacy.

Refusing to permit the applicant to introduce fresh medical documents at the review stage, the Court observed that a party cannot fill gaps in its case through review proceedings. It held that the materials now sought to be relied upon were within the applicant's knowledge when the writ petition was argued and therefore could not form the basis for review.

Emphasising the limited scope of review jurisdiction under Order XLVII of the Code of Civil Procedure, the Bench said, "an appeal under the disguise of review should not be entertained." It added that the applicant had sought to re-appreciate the entire case as though the Court was sitting in appeal over its own judgment. The Court ultimately dismissed the review application and declined to impose costs only because the applicant was a student.

Case Title: Ankita Jagannath Sonawale v. Maharashtra National Law University Through its Registrar and Others

Date of Judgment: June 18, 2026

Bench: Justice Vibha Kankanwadi and Justice Ajit B. Kadethankar