PhD Programme Cannot Be Cancelled Without Due Process: Madhya Pradesh High Court

The Madhya Pradesh High Court has set aside the termination of a PhD scholar’s programme at the Pt Dwarka Prasad Mishra Indian Institute of Information Technology Design and Manufacturing Jabalpur holding that the action violated the principles of natural justice as no proper show cause notice or opportunity of hearing was granted before cancelling the programme of petitioner Amir Azad Ansari.

A division bench of Justice Vivek Rusia and Justice Pradeep Mittal allowed the writ petition filed by Ansari challenging orders dated May 15, 2025 and May 23, 2025 through which the institute terminated his PhD programme under Clause 14(b)(iv) of the PhD Manual citing alleged unauthorized absence and unsatisfactory academic performance and research progress.

The court noted that the petitioner had been admitted to the doctoral programme in May 2022 and the decision to terminate his enrolment was taken by the Discipline Post Graduate Committee after considering a report from his supervisor Dr Prashant K Jain regarding alleged absence and poor performance during the semester.

However, the bench found that the institute had not issued any proper show cause notice informing the scholar that termination of the programme was being contemplated nor was he granted a meaningful opportunity to present his explanation before the drastic action was taken.

The judges recorded that the respondents themselves admitted in their reply that no formal hearing preceded the impugned decision and reliance was placed only on an email sent to the petitioner seeking clarification regarding his performance.

The court observed that such communication could not substitute the requirement of a proper notice proposing termination. It remarked that “before taking the impugned action of termination of the PhD programme a proper show cause notice should have been issued calling upon the student to submit reply or explanation.”

The bench further emphasized that if disputed questions of fact existed regarding absence or academic progress the authorities were required to conduct a fact-finding enquiry and permit the student to produce evidence in his defence before reaching any adverse conclusion.

Rejecting the institute’s objection that the petition was not maintainable because the PhD Manual provided an appellate remedy before the Chairperson of the Senate, the court held that such remedy could not be considered effective when the initial decision itself was taken without following the principles of natural justice.

The bench observed that merely sending an email or asking a student to appear before a committee without disclosing the intention to terminate the programme cannot be treated as compliance with procedural fairness.

Holding the action legally unsustainable the High court quashed the termination order dated May 15, 2025 and the corrigendum issued on May 23, 2025.

“Until and unless such an inquiry is conducted and a decision is taken the remedy of appeal cannot be said to be an effective remedy” the court said while allowing the petition.

As a result, the petitioner’s challenge succeeded and the impugned orders were set aside though the institute has been granted liberty to proceed afresh in accordance with law and after complying with due process.

The court clarified that academic institutions certainly possess the authority to regulate research programmes and enforce discipline but such power must be exercised in a fair and transparent manner particularly when a student’s academic career and future prospects are at stake.

Appearing for the petitioner was advocate Takmeel Nasir while advocate Veer Vikrant Singh represented the respondents before the High Court.

Case Title: Amir Azad Ansari v. Pt. Dwarka Prasad Mishra Indian Institute of Information Technology Design and Manufacturing Jabalpur and Others

Date of Order: March 10, 2026

Bench: Justice Vivek Rusia and Justice Pradeep Mittal