Right to Appear in Exam Is Part of Article 21: Allahabad HC Orders Special Exam for B.Sc Student

The Allahabad High Court has directed Prof. Rajendra Singh (Rajju Bhaiya) University, Prayagraj, to conduct a special examination for a B.Sc. (Biology) first-year student who was denied an admit card due to non-updation of her records on the University’s online portal, despite there being no fault on her part.

The bench of Justice Vivek Saran passed the direction while hearing a writ petition filed by Shreya Pandey, a student of Urmila Devi P.G. College, Prayagraj, who had approached the court after being barred from appearing in the first semester examination for the academic session 2025–2026.

According to the petitioner, she had taken admission in the B.Sc. (Biology) course for the 2025–2026 session and deposited the requisite fees with the college on July 16, 2025. She thereafter attended classes and pursued her studies in the normal course. However, when the University issued the examination schedule, she was not provided with an admit card, effectively preventing her from appearing in the examination.

The petitioner submitted a representation on November 27, 2025, addressed to the Vice-Chancellor of the University through the principal of the college, seeking redressal of her grievance. It subsequently emerged during the proceedings that while her application existed on the University’s Samarth Portal, it had remained in “draft” form and was not formally updated within the prescribed time.

The University, represented by its counsel, contended that the petitioner’s records were not updated on the Samarth Portal within the stipulated deadline and that although the portal was reopened between October 31 and November 1, 2025, the necessary updation was not completed. It was argued that in the absence of complete and updated records on the portal, the University could not have issued an admit card.

On the other hand, the college submitted that there were several students whose records had not been updated due to technical issues. The college informed the University about this problem through a written communication dated October 22, 2025, which was received by the University on October 27, 2025. Out of nearly 30 students whose names were forwarded, records of 25 students were subsequently corrected, but the petitioner’s record, along with that of four others, remained unupdated.

After examining the material on record, court noted that the petitioner’s application was available on the Samarth Portal in draft form and that the University was aware of the issue regarding non-updation of her records. Court observed that despite having such knowledge, the University authorities did not take appropriate steps to resolve the technical lapse. Court further noted that no procedure was explained by the University as to how such technical errors are dealt with once they are brought to its notice.

Relying on its earlier decision in Rahul Pandey vs Union of India and three others, which held that the right to appear in an examination is part of the right to life under Article 21 of the Constitution, and the Delhi High Court ruling in Re: Master Prabhnoor Singh Virdi (Minor Son) vs Indian School and Another, the court held that the petitioner’s future could not be jeopardised due to technical or administrative lapses not attributable to her.

As an interim measure, court directed the University to conduct a special examination for the petitioner for the B.Sc. (Biology) first semester within two weeks and to declare the result within a reasonable time thereafter, enabling her to continue her studies. Court also directed the University to update the petitioner’s records on its system within a reasonable period to ensure that such issues do not affect her future academic progression.

Case Title: Shreya Pandey vs. State Of U.P. And 2 Others

Order Date: January 12, 2026

Bench: Justice Vivek Saran