Can a Student Claim a University Gold Medal as a Legal Right? Madras High Court Says No

Dealing with a challenge by a batch topper denied a university gold medal for not clearing all papers in the “first attempt”, the Madras High Court recently held that the award of such academic honours does not involve any enforceable legal right. The high court also expressly declined to follow a contrary interpretation adopted by the Delhi High Court that absence due to illness cannot be treated as a second attempt in examinations.

The bench of Justice D Bharatha Chakravarthy was dealing a writ petition filed by H Vennila, a former student of Bharathidasan Government College for Women, Puducherry, who challenged the denial of a gold medal for the B.Com (Corporate Secretaryship) course for the academic years 2015–2018.

The petitioner had secured 2014 marks out of 2600, emerging as the highest scorer in her batch. However, the gold medal was awarded to another student, Vijayalakshmi, who had scored 1923 marks, 109 marks fewer than Vennila. The petitioner’s representation seeking reconsideration was rejected by the college in November 2021, leading her to approach the high court.

The denial of the gold medal was based on the ground that Vennila had not cleared all examinations in the “first attempt,” as required under a circular issued by Pondicherry University on June 4, 2018. She had been absent for one examination in the first semester and appeared for the paper in the subsequent examination.

Before the court, Vennila argued that her absence was due to dengue fever and that she cleared the paper at the first available opportunity. She contended that absence due to illness could not be equated with a second attempt and relied on the judgment of the Delhi High Court in Abhinav Pandey and Guru Gobind Singh Indraprastha University and others (2016) where the high court had accepted such reasoning.

Opposing the petition, the university and the Puducherry government submitted that the award of a gold medal was not a statutory entitlement but part of an academic scheme governed by specific eligibility conditions. They argued that the university circular clearly required students to pass all examinations in the first attempt, and that the rule had been applied uniformly to all candidates, irrespective of whether a student failed or was absent in the first instance.

Justice Chakravarthy noted that the term “first attempt” was not defined either in the circular or in any statute, and therefore could not be given a rigid or universal meaning. He observed that while the Delhi High Court had taken the view that absence on medical grounds should not be treated as an attempt, such an interpretation could not be mechanically applied in all cases.

The judge pointed out that the conferment of a gold medal is intended to recognise academic excellence and motivate students, but does not involve a legal right capable of enforcement through writ jurisdiction. In such circumstances, he said, the meaning assigned to eligibility conditions like “first attempt” should ordinarily be left to academic authorities, particularly when a uniform standard is being applied across the board.

Expressing disagreement with the Delhi High Court’s approach, court reasoned that individual choices and circumstances vary among students. It noted that another student suffering from illness might still choose to appear for an examination and score lower marks as a result. Treating absence differently, court said, could raise questions of fairness rather than resolve them, and could not be tested on equality principles alone.

Court also took into account that the gold medal had already been awarded to the fifth respondent several years earlier and that reopening the issue at this stage would be unfair to her and other students who had received the honour.

At the same time, Justice Chakravarthy acknowledged the petitioner’s exceptional academic performance, noting that she had scored well above the next candidate and would still have remained ahead even if marks for the disputed paper were excluded. Considering these peculiar circumstances, and the fact that the college has since become an autonomous institution, court directed the college to issue Vennila an academic certificate on merit recognising her as a gold medallist, in the same format as issued to the other student.

The writ petition was disposed of with this direction, without costs.

Case Title: H.Vennila vs. State and Others

Order Date: January 21, 2026

Bench: Justice D Bharatha Chakravarthy