Draft | 'Students Await While University and St Stephen’s College Vehemently Contest Each Other': Delhi HC In Seat Matrix Dispute

The Delhi High Court bench of Justice Swarana Kanta Sharma, recently, in the dispute between Delhi University and St Stephen’s College over seat matrix remarked that “the students await the outcome of the judgment in the corridors of this Court while the college and the university are contesting each others claim vehemently”.

Multiple students, including one Vanya Malik, applied for the Common University Entrance Test (CUET) 2024, held by the Respondent no 2, National Testing Agency (NTA) from May 15 to May 24, 2024, with a rescheduled test on May 29. On August 16, 2024, the first Common Seat Allocation System (CSAS) allocation list was released, and the students were allocated seats, which they accepted promptly by August 18. Respondent no 3, St. Stephen's College was required to verify and approve their online applications between August 16 and August 20, with the fee payment deadline set for August 21 at 4:59 PM.

Despite the students submitting all required documents, the College neither approved nor rejected their applications. As a result, the students were unable to pay the fees and secure their seats at St. Stephen's. This inaction also prevented them from opting for their next preferred college, despite meeting the eligibility criteria. Consequently, the students faced difficulties in securing admission to any college. Frustrated by these circumstances and fearing the loss of an academic year through no fault of their own, the students were compelled to seek relief.

Senior Advocate Rishi Malhotra, representing the students, argued that despite meeting all application requirements, the students were left in limbo as St. Stephen’s College neither accepted nor rejected their applications. This inaction prevented them from paying fees or considering other options, causing significant hardship. Senior Advocate Malhotra also criticized the college's misrepresentation of the seat allocation process, clarifying that a 5% increase in seats should apply to each sub-program and that any fractional seat numbers should be rounded up according to university policy. He highlighted that once an applicant's college and program preference was locked, they couldn't switch, exacerbating the issue.

On the other side, Senior Advocates Romy Chacko and A. Mariarputham for St. Stephen’s College argued that, as a Minority Educational Institution, the college was exempt from state reservation policies under Article 30 of the Constitution. Historically, the college had its own admission process but had agreed to a 50-50 split between CUET scores and Christian student admissions in 2022. The college claimed Delhi University exceeded the agreed 5% excess seat allocation in several programs, including BA (Hons.) Economics, and admitted students beyond the permissible intake.

Advocate Mohinder J.S. Rupal for Delhi University contended that St. Stephen’s should not have denied admission after the students were selected. Advocate Rupal asserted that the college should have raised any concerns about seat allocation before the admission process began. The University argued that the claims of over-allocation were unfounded and that any admissions issues stemmed from the College's mismanagement, not University policies.

The court framed the following issues:
“(1) Whether the thirteen B.A. programs offered by St. Stephen’s College should be treated as distinct and separate programs, or as a single unified B.A. program for the purposes of seat allocation/admission under the Christian Minority category and Unreserved category?
(2) Whether Delhi University could have allocated 5% extra students to the respondent College, which has been challenged in the Additional Counter Affidavit and during Arguments by the respondent College, and whether such an allocation was in accordance with the agreed terms?
(3) Whether, in determining the 5% extra seat allocation, fractions below 0.5 should be rounded off to the lower side or the higher side? W.P.(C) 11695/2024 & connected matter Page 24 of 54
(4) Whether this Court has the jurisdiction, in the present petition, to adjudicate the validity and constitutionality of the 'Single Girl Child Quota' as implemented by Delhi University?
(5) Whether the petitioners should be denied admission to the respondent College despite fulfilling all requirements, solely due to a dispute or misunderstanding between the College and the University, which was beyond the petitioners’ control?”

The court noted that in the 2023-24 academic session, St. Stephen's College offered a single unified B.A. program, but for 2024-25, it introduced thirteen distinct B.A. programs, each with separate seat allocations and cut-off marks. The court noted that the seat matrix for these programs was prepared by the college and posted by Delhi University in the Bulletin, with a disclaimer indicating contributions from the college.

The court observed that the matrix indicated distinct programs with individual seat allocations and cut-offs, contrasting with colleges offering a single B.A. program that uses a consolidated cut-off list. The court rejected the college's argument that these programs were merely variations of a single B.A. program, affirming that they should be treated as separate entities for admissions.

Per the court’s observations, the bulletin stated that seat allocation would be managed through the CSAS, validated by the Executive Council's Resolution No. 13 (13-45) from July 27, 2024. Despite being aware of and previously complying with CSAS, the college did not challenge its use for the 2024 admissions. The CSAS policy allowed additional student allocation in early rounds, which the college had agreed to in previous years and for the current session.

The court determined that fractions less than 0.5 should be rounded up to the next whole number, rather than down, to align with the policy’s intent. The college argued that, as a minority institution, it could set its own admission policies under Article 30(1) of the Constitution and cited infrastructure limitations for accommodating additional students. However, the court noted that the college had previously accepted higher allocations and had requested a 5% extra allocation for the Christian category.

The court concluded that students, who had complied with admission procedures and were allocated seats, had a legitimate expectation for admission. The college’s delay in approving applications due to disputes with the University unfairly denied these students their right to admission.

“This case has travelled and reached the end of the tunnel of litigation before this Court, where the petitioners were unsure of their future and admission in the college of their choice for which they have worked so hard. Fortunately, they have light at the end of this tunnel”, the court outlined.

The court further stressed that educational institutions should focus on effective administration and teaching, rather than defending their positions in court. To resolve disputes efficiently, timely meetings and clear solutions are essential, the court added.

Consequently, the court did not invalidate nor find fault with the University’s method of calculating seat numbers by rounding up fractions. St. Stephen’s College was directed to admit the students according to the University’s allocation policy, which the college had adhered to in previous academic years. The students were to be allowed to attend their classes upon completing other necessary formalities per the relevant rules. For Vanya Malik, it was directed that both Delhi University and the college should take the necessary measures to open the fee portal, allowing her admission to the college.

Case Title: Hargun Singh Ahluwalia & Ors v Delhi University (2024:DHC:6844)