'National In Dire Need for Research Work': Allahabad High Court Orders PhD Student's Admission Reinstated

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Synopsis

Court held that in absence of any allegations of misrepresentation or fraud by the student, blocking his five-year effort would be a loss not just to him but to the country as a whole

In a significant judgment, the Allahabad High Court recently held that a student who has completed five years of a PhD program cannot be denied completion of the degree due to alleged admission irregularities.

The bench of Justice Alok Mathur, while granting relief to the petitioner-student, emphasized that the nation's journey from a developing to a developed country hinges on extensive research efforts.

He pointed out the injustice of halting students' research progress over technical legalities when they are on the cusp of completion. The judge stressed the importance of research, noting that blocking a student’s five-year effort would be a loss not just to the individual but to the country as a whole.

"The country is in dire need of research work. Petitioner has put more than five years in his Ph.D. course and is on the verge of submitting the same. Now denial of benefit of said research work to the nation in itself would be a huge loss," said Justice Mathur.

The petitioner, a law graduate, had been admitted to a PhD program in Sociology at Dr. Shakuntala Misra National Rehabilitation University, Lucknow, after passing an entrance test in 2016. However, it wasn’t until 2021 that when the petitioner sought additional time from his supervisor to submit a required report, the supervisor refused to accept it and asked the petitioner to await further instructions. But, subsequently, the petitioner was barred from continuing his PhD.

The petitioner approached the court, which directed the Vice-Chancellor of the university to address his concerns. Eventually, in an order dated October 6, 2022, the university cancelled his admission, citing the petitioner’s failure to provide an affidavit that had been requested multiple times.

The petitioner’s counsel argued that the petitioner had been properly admitted after clearing the entrance test, as evidenced by his admit card and records from the 2016-17 academic session.

Conversely, the university’s counsel contended that the petitioner had not met the entrance test qualifications and that his admission was annulled due to the absence of the required affidavit.

The high court observed that the petitioner’s name was listed among PhD scholars for the 2016-17 session and noted that he had been continuously enrolled in the program from 2016 to 2022.

Referring to the Supreme Court’s ruling in *Rajendra Prasad Mathur v. Karnataka University*, which placed the responsibility for wrongful admissions on educational institutions rather than students, court concluded that the petitioner’s admission, having been valid for five years, could not be revoked when he was nearing completion.

Court found that even if there had been irregularities during the petitioner’s admission, these should not be grounds for denying him the opportunity to complete his course.

In the absence of any allegations of misrepresentation or fraud by the petitioner, court held that the university could not cancel his admission. Court directed it to grant the petitioner an extension in line with the rules.

Resultantly, court allowed the petition and quashed the orders passed by the Research Degree Committee and the Registrar in 2022 and 2023 respectively.

Case Title: Mithilesh Kumar Chaudhary v. State Of UP and Others