Madhya Pradesh High Court
Himanshu Sharma vs The State Of Madhya Pradesh on 17 March, 2026
NEUTRAL CITATION NO. 2026:MPHC-IND:7311
1 W.P. No. 6652/2026
IN THE HIGH COURT OF MADHYA PRADESH A T
INDORE
BEFORE
HON'BLE SHRI JUSTICE JAI KUMAR PILLAI
WRIT PETITION No. 6652 of 2026
HIMANSHU SHARMA
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Ashish Choubey - Advocate for the petitioner
Shri Kushagra Singh - Deputy Government Advocate through V.C
Shri Vivek Sharan - Senior Advocate alongwith Shri Rahul Maheshwari -
Advocate for the respondent No.2.
Reserved on : 12/03/2026
Post on : 17s /03/2026
______________________________________________________
ORDER
The present writ petition has been filed by the petitioner under Article 226 of the Constitution of India, invoking the extraordinary writ jurisdiction of this Court. The petitioner is Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 2 W.P. No. 6652/2026 aggrieved by and seeks the quashing of the impugned communication/order dated 30.01.2026 issued by Respondent No. 2, whereby the petitioner has been placed under the category of "YD" (Year Down). Furthermore, the petitioner seeks a writ of mandamus directing the respondents to permit him to continue his studies in the Second Year (Fourth Semester) of the Bachelor of Business Administration (Banking, Financial Services and Insurance Management) Programme.
Facts of the Case
2. The petitioner was admitted to Respondent No. 2 (Symbiosis University of Applied Science, Indore), a Self-financed University established under the Madhya Pradesh Niji Vishwavidyalaya Adhiniyam, 2017, in the Bachelor of Business Administration Programme for the academic session commencing in the year 2024.
3. The petitioner appeared in the First Year Examinations but was declared unsuccessful in the Second Semester Examination. Consequently, the respondent University permitted the petitioner to avail the benefit of ATKT (Allowed to Keep Terms) and allowed him to submit the application Form to clear the backlog papers.
Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36NEUTRAL CITATION NO. 2026:MPHC-IND:7311 3 W.P. No. 6652/2026
4. Subsequently, on 11.12.2025, the petitioner received an e-mail from the University informing him that he had not met the mandatory attendance criteria and, accordingly, was being placed on Term Not Granted (TNG) for the current semester.
5. In a related writ petition (W.P. No. 46548/2026) filed by a similarly situated student, this Court, vide order dated 14.12.2025, recorded a proposal tendered by the Pro-Chancellor of the University and directed the management to permit the petitioner therein, as well as other students on a similar footing, to appear in the III Semester examination. In compliance with the said judicial direction, the respondent University permitted the petitioner to appear in the End Semester Theory Examinations as a one-time special measure.
6. The petitioner duly appeared in the said Examination. Thereafter, the respondent University issued the impugned communication dated 30.01.2026.
7. A perusal of the impugned communication dated 30.01.2026 reveals that the result of the said Examination was declared. The communication explicitly informed the petitioner that based on his Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 4 W.P. No. 6652/2026 overall combined result he had failed to individually pass under the three mandatory assessment heads prescribed in Clause 3.3 of the Student Handbook, leading to his placement under the "YD" (Year Down) category as per Clause 3.6.3 of the Handbook.
Contentions of the Petitioner
8. On merits, the petitioner contends that having permitted him to appear in the Third Semester End-Term Examinations pursuant to the orders of this Court, the University could not have abruptly placed him under the "YD" category.
9. The petitioner further asserts that the declaration of a student as "YD" presupposes an objective determination. The petitioner pleaded that the respondent arbitrarily categorized him as "YD" without communicating any assessment of his performance and therefore, the action is contrary to the University's own Handbook and hit by the doctrines of legitimate expectation and promissory estoppel.
Contentions of the Respondents Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 5 W.P. No. 6652/2026
10. The respondents have opposed the petition, submitting that the action taken is strictly in accordance with the governing rules. It is the categorical stand of the respondent University that the result of the examination was indeed declared and communicated to the petitioner.
11. The respondents contend that the petitioner failed to individually pass the three mandatory assessment heads prescribed under Clause 3.3. Consequently, the petitioner failed to fulfill the minimum academic requirements and earn the necessary credits, leading to the statutory application of the "YD" category under Clause 3.6.3. Therefore, the petition is devoid of merit.
Analysis and Conclusion
12. Having heard the pleadings as summarized above and upon a careful perusal of the record, the core issue before this Court is whether the impugned communication dated 30.01.2026, placing the petitioner in the "YD" category, warrants any interference under Article 226 of the Constitution of India.
13. It is an admitted position that the academic progression of the students in the respondent University is strictly governed by the Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 6 W.P. No. 6652/2026 Student Handbook. To adjudicate the present controversy, it is apposite to reproduce the relevant extract of Clause 3.6 of the Evaluation System, titled "Rules for Granting Term, Term Not Granted (TNG) and Year Down (YD)", which reads as under:
"3.6.1 Criteria 1: 100% attended for Skills and Practical and 75% in Lecture and Tutorials 3.6.2 Criteria 2: Completed term work of all subjects, i.e., project, skills, and practical journal, internship report and should be duly signed by the concerned subject teacher and also attending and passing all Unit Test.
3.6.3 Criteria 3: Earned at least 50 % credits of Current Academic Year (CAY) & 100 % credits of CAY-2 (E.g. all clear in First Year for Third year admission) YD- A student who fails to fulfill Criteria 1 and Criteria 2 or Criteria 3 then he/she cannot be promoted to the next academic Semester/Year. Such student will not be permitted to proceed to the subsequent Semester/Year and will be required to complete the semester by taking re-admission in the next academic year with the junior batch and fulfill Criteria 2. He/she needs to appear for a backlog examination and is required to earn the necessary credits as mentioned in Criteria 3 to become eligible for next Academic Year"
14. The primary contention of the petitioner--that he was placed in the "YD" category without his result being declared--is factually incorrect and is squarely belied by the record. The explicit language Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 7 W.P. No. 6652/2026 of the impugned communication dated 30.01.2026, extracted in the pleadings, unequivocally states: "In pursuance of the same, you had appeared in the said examination and the result thereof has been declared."
15. The impugned communication clearly delineates the reasons for the petitioner's academic categorization. It records that based on the overall combined result, the petitioner failed to individually pass the three mandatory heads stipulated under Clause 3.3. As a direct and inescapable corollary of failing these substantive assessments, the petitioner failed to earn the minimum necessary credits required under Criteria 3 of Clause 3.6.3.
16. The petitioner's reliance on the interim permission granted by this Court to appear in the Examination is fundamentally misplaced. The impugned letter rightly notes that the permission was a "one- time special measure" granted in consonance with an interim judicial order. Participation in an Examination under the protective umbrella of a Court order merely affords the student an opportunity to perform; it does not, by any stretch of imagination, operate as a waiver of the substantive academic passing criteria explicitly laid down in the University's Handbook.
Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:47:36NEUTRAL CITATION NO. 2026:MPHC-IND:7311 8 W.P. No. 6652/2026
17. The categorization of the petitioner as "YD" on 30.01.2026 is an inexorable consequence of his failure to qualify under Clause 3.3 and Clause 3.6.3 on his own academic merit. In matters of academic standards and institutional evaluation, Courts must exhibit profound restraint and defer to the domain experts unless the action is patently arbitrary or malafide. The impugned order dated 30.01.2026 is found to be a reasoned communication passed in strict conformity with the specific mandate of the Student Handbook.
18. In view of the elaborated analysis, this Court finds no illegality, irregularity, or arbitrariness in the impugned action of the respondents.
19. The writ petition, being devoid of merit, is accordingly dismissed.
Pending applications, if any, shall also stands disposed of, accordingly. No order as to costs.
(Jai Kumar Pillai)
Judge
Signature Not Verified
Signed by: RASHMI
PRASHANT
Signing time: 17-03-2026
18:47:36
NEUTRAL CITATION NO. 2026:MPHC-IND:7311
9 W.P. No. 6652/2026
rashmi*PS
Signature Not Verified
Signed by: RASHMI
PRASHANT
Signing time: 17-03-2026
18:47:36