Madhya Pradesh High Court
Anushka Sahani vs The State Of Madhya Pradesh on 17 March, 2026
NEUTRAL CITATION NO. 2026:MPHC-IND:7311
1 W.P. No. 6338/2026
IN THE HIGH COURT OF MADHYA PRADESH
AT INDORE
BEFORE
HON'BLE SHRI JUSTICE JAI KUMAR PILLAI
WRIT PETITION No. 6338 of 2026
ANUSHKA SAHANI
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Ashish Choubey - Advocate for the petitioner
Shri Kushagra Singh - Deputy Government Advocate for the
respondents State.
Shri Vivek Sharan - Senior Counsel with Shri Rahul Maheshwari -
Advocate for the respondent No.2.
Reserved on : 12/03/2026
Post on : 17/03/2026
______________________________________________________
ORDER
This writ petition under Article 226 of the Constitution of India has been instituted by the petitioner seeking a writ in the Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 2 W.P. No. 6338/2026 nature of Certiorari to quash the impugned communication dated 30.01.2026 (Annexure-P/7) issued by Respondent No. 2, whereby the petitioner has been placed under the "YD" (Year Down) category. The petitioner further seeks a writ in the nature of Mandamus to direct 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 Bachelor of Business Administration Programme at respondent No.2 University for the academic session commencing in 2024. The petitioner successfully qualified the First Year examinations, securing a Semester Grade Point Average (SGPA) of 6.8125.
3. Subsequently, the petitioner was admitted to the Second year (Third Semerster). During this semester, the petitioner's attendance fell below 30%. The respondent University granted the petitioner an opportunity to attend remedial classes for a period of two weeks, which the petitioner duly attended.
Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51NEUTRAL CITATION NO. 2026:MPHC-IND:7311 3 W.P. No. 6338/2026
4. Prior to the commencement of the First Unit Test, the respondent University issued a list debarring certain students including the petitioner, from appearing in the said test. Thereafter, vide communication dated 14.11.2025, the petitioner was informed that his admission for the Academic Year 2025-2026 stood cancelled on the grounds of absence in the First and Second Unit Tests and his overall attendance falling below the minimum prescribed requirement.
5. In a similarly situated matter (Writ Petition No. 48548 of 2025, this Court passed an order on 14.12.2015. Based on a proposal by the Pro-chancellor of the University, this Court directed the Management to permit the petitioner therein, as well as students on a similar footing, to appear in the III Semester examination commencing from 15.12.2025.
6. In compliance with the aforesaid judicial direction, the petitioner appeared in the End Semester Examination. However, without declaring the result of the said examination, Respondent No. 2 issued the impugned communication dated 30.01.2026, categorizing the petitioner as "YD" (Year Down).
Contentions of the Petitioner Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 4 W.P. No. 6338/2026
7. It is contended on behalf of the petitioner that Respondent No. 2 is an instrumentality of the State under Article 12 of the Constitution of India, as it functions under the regulatory control of the UGC, and its Governing Body and Board of Management include State Government nominees.
8. The petitioner submits that the impugned action is contrary to Clause 3.6 of the Student Handbook issued by the University itself. The petitioner asserts that the "YD" categorization requires a failure to fulfill Criteria 1, 2 or 3. Since, the petitioner was expressly permitted to appear in the examination pursuant to the orders of this Court , and no result has been declared, there is no factual or lawful basis to conclude that the prescribed criteria were not met. The petitioner further contends that the unilateral cancellation of admission and subsequent "YD" categorization are arbitrary, violative of the principles of natural justice and hit by the doctrine of legitimate expectation and promissory estoppel.
Contentions of the Respondents
9. Per contra, the respondents have opposed the petition. It is the categorical stand of the respondents that the actions taken against the petitioner including the categorization under "YD", are Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 5 W.P. No. 6338/2026 strictly in accordance with the governing rules and academic standards proscribed by the University in its Student Handbook, and no interference is warranted.
Analysis and Conclusion
10. Heard the pleadings advanced and perused the record.
11. The seminal issue for consideration before this Court is whether the impugned communication dated 30.01.2026, placing the petitioner in the "YD" category, is arbitrary or in contravention of the University's prescribed rules, thereby warranting interference a\under Article 226 of the Constitution of India.
12. To appreciate the controversy, it is apposite to reproduce the exact regulatory framework governing the academic progression of the students, as stipulated in Clause 3.6 of the Student Handbook issued by the respondent University Academic Year 2025-26:-
―3.6.1 Criteria 1: 100% attended for Skills and Practical and 75 % in Lecture and Tutorials.Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51
NEUTRAL CITATION NO. 2026:MPHC-IND:7311 6 W.P. No. 6338/2026 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)‖
13. The consequences of failing to meet the aforementioned criteria are further codified in the same clause under the specific heading of "YD", which reads verbatim as under:
―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‖ Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 7 W.P. No. 6338/2026
14. A plain reading of the aforesaid statutory stipulations makes it abundantly clear that the mandate of the University regulations is absolute. For a student to be promoted, they must fulfill the minimum prescribed attendance (Criteria 1) and successfully complete the continuous evaluation components, including attending and passing all Unit Tests (Criteria 2). The "YD" rule explicitly states that a failure to fulfill Criteria 1 and Criteria 2 renders the student ineligible for promotion.
15. Applying these exact rules to the admitted facts of the present case, it is an undisputed position on record that the petitioner's attendance during the third semester had fallen to below 30%, which is in gross violation of the 75% mandate prescribed under Clause 3.6.1 (Criteria 1). Furthermore, the University's communication dated 14.11.2025 categorically recorded that the petitioner remained absent in the First Unit Test as well as the Second Unit Test. Consequently, the petitioner unequivocally failed to satisfy the condition of "attending and passing all Unit Test" as rigidly required under Clause 3.6.2 (Criteria 2).
16. The petitioner's contention that the "YD" status could not be invoked without declaring the end-semester examination Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 8 W.P. No. 6338/2026 result is misconceived and runs contrary to the scheme of the Handbook. The failure to fulfill Criteria 1 (attendance) and Criteria 2 (Unit Tests) operates as a distinct and independent bar to academic progression. The rule governing "YD" is triggered by the failure to fulfill these continuous evaluation metrics, irrespective of the outcome of the end-semester examination.
17. Furthermore, the argument that the interim permission granted by this Court vide order dated 14.12.2025 in W.P. No. 48548/2025 acts as an estoppel against the University is legally untenable. An interim or ad-hoc arrangement permitting a student to merely appear in an examination does not, and cannot, operate to wash away or waive the substantive statutory academic deficiencies--namely, the drastic shortfall in attendance and the failure to appear in mandatory Unit Tests. The mandate of the rule remains undisturbed.
18. In view of the rigorous and unambiguous phraseology of Clause 3.6 of the Student Handbook, this Court finds that the respondent University had no alternative but to classify the petitioner as "YD". The impugned order dated 30.01.2026 is, Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51 NEUTRAL CITATION NO. 2026:MPHC-IND:7311 9 W.P. No. 6338/2026 therefore, a natural, necessary, and lawful corollary of the petitioner's failure to satisfy Criteria 1 and Criteria 2.
19. The action of the respondents is found to be strictly in consonance with the governing academic rules. No case of arbitrariness, unreasonableness, or violation of principles of natural justice is made out to warrant interference by this Court in the exercise of its extraordinary jurisdiction under Article 226 of the Constitution of India.
20. Consequently, the writ petition, being devoid of merit, fails and is hereby dismissed.
Pending applications, if any, shall be disposed of accordingly. No order as to costs.
(Jai Kumar Pillai) Judge rashmi*PS Signature Not Verified Signed by: RASHMI PRASHANT Signing time: 17-03-2026 18:35:51