Telangana High Court
Kataru Satya Sai vs The Indian Institute Of Management ... on 20 April, 2026
Author: Nagesh Bheemapaka
Bench: Nagesh Bheemapaka
IN THE HIGH COURT OF JUDICATURE FOR THE STATE OF
TELANGANA
HON'BLE SRI JUSTICE NAGESH BHEEMAPAKA
WRIT PETITION No. 3063 OF 2026
20.04.2026
Between:
Kataru Satya Sai
..... Petitioner
And
The Indian Institute of Management Mumbai,
Rep. by its Director & others
..... Respondents
O R D E R:
Petitioner states that the Convenor of CAT-2025 issued Notification dated 30.07.2025 for entrance test for admission into MBA programmes to various prestigious IIM for the academic year 2026-27. In response, petitioner, a graduate in B.E./B.Tech applied on line as per the procedure prescribed therefor. He received an Admit Card from CAT-2025 from IIM, Kozhikode to participate in the test to be held on 30.11.2025 in Hyderabad. Accordingly, he participated in the test and secured 99.73 percentile in Verbal Ability and Reading Comprehension (VARC), 92.87 percentile in Data Interpretation & Logical Reasoning (DI&LR) and secured 98.66 percentile in Quantitative 2 Ability (QA) and the overall percentile is 99.52 and the score is valid till 31.12.2026.
1.1. It is relevant, according to petitioner, to state that the Ministry of Law and Justice (Legislative Department) of Indian Government issued a Gazette Notification dated 31.12.2017 under Act No. 33 of 2017 called as 'the Indian Institution of Management Act, 2017, a Central Act, declaring about 20 IIMs. as national institutions with an objective to educate and support leads who can contribute as professional managers, entrepreneurs in private, public and social sectors and also provide management education of high quality and to promote allied areas of knowledge as well as interdisciplinary studies etcetera. It is stated, subsequently, the IIM, Mumbai issued Notification dated 29.11.2024 under the 2017 Act and also issued Regulations for admission into post graduate courses. Accordingly, IIM, Mumbai was constituted under the Central Act and it comes within the definition of Article 12 of the Constitution, hence Writ Petition is maintainable. 1.2. It is further stated, petitioner opted for other IIMs along with IIM, Mumbai but the other top IIMs. such as IIMs at Calcutta, Bangalore gave mail communication in the 2nd week of January 2026 to petitioner regretting that he was not shortlisted 3 for Personal Interview, similarly, other IIMs also communicated that petitioner was not shortlisted. Petitioner therefore, is stated to have sent two mails on 20.01.2026 and 21.01.2026 seeking clarity on selection criteria and his own status of selection for stage II process, but so far, no reply was received from Respondent No.1.
2. While issuing notice before admission, this Court by order dated 03.02.2026 granted interim direction as prayed for.
3. Seeking to vacate the said order, Respondents 1 and 2 had taken out I.A.No.2 of 2026, along with it they filed counter-affidavit. It states that Writ Petition is not only barred by lack of territorial jurisdiction but since IIM, Mumbai does not qualify as 'State', no Writ Petition can lie against the orders passed by it. If petitioner had any grievance against respondents, he ought to have approached the Court having territorial jurisdiction over IIM, Mumbai. It is stated that the financials clearly establish that the Institute overwhelmingly relies on internal revenue and not on government grants. In support of this contention, respondents have annexed to the counter the annual accounts of the institute which shows that there was an expenditure of Rs.106,05,17,921/-, out of which, majority of funds i.e. Rs.75,20,17,921/- were generated internal 4 and Rs. 30,85,00,000/- shown as 'grants and subsidies' in the Annual Accounts for 2024-25 was not a recurring grant, but only the balance of pre-transition NITIE support released after the Institute's conversion into an IIM and it does not represent any continuing budgetary funding.
3.1. It is also stated, petitioner is attempting to portray that if he clears the minimum CAT percentile cut-off with sectional cut-off, he shall be considered for Personal Interview, however, as per the proviso to the Admission Policy for the MBA Programme (Batch 2026-28), the actual section-wise and overall percentile cut-offs may be much higher. The relevant proviso says that by merely clearing the minimum cut-offs, petitioner does not automatically become eligible for Stage-II i.e. shortlisting for Personal interview as it will depend upon the number of candidates to be called in each category. Since large number of applications were received by IIM, Mumbai, they had to increase the section -wise and percentile- cut offs. The section-wise cut-off for DILR for General (Male) category for MBA programme was 93.50 percentile, however, since petitioner secured 92.87 percentile, he was ineligible to qualify for stage II process. Since petitioner did not clear the stage I process, and communication was addressed to him and there is also no 5 obligation on the part of IIM, Mumbai to address any personal correspondence to any of its members be a rank outsider such as petitioner.
4. Learned counsel for petitioner Sri M.R. Tagore submits that IIM, Mumbai being a statutory public authority is bound by its Constitution and denial of short-listing to stage-II process despite fulfilling all published criteria by his client while granting it to the similarly-placed candidates without intelligible differentia amounts to arbitrariness and unequal treatment. On the maintainability of the Writ Petition, he relied on the judgment of the Hon'ble Supreme Court in Anandi Mukta Sadguru Shree Mukta v. V.R. Rudani 1 and contends that judicial control over the fast expanding maze of bodies affecting the rights of the people should not be put into water-tight compartment. It should remain flexible to meet the requirements of variable circumstances. Mandamus is a very wide remedy which must be easily available to reach injustice wherever it is found. Technicalities should not come in the way of granting that relief under Article 226.
5. Sri Adhitya Iyer, learned counsel representing Sri Kamesh Vedula, learned counsel for Respondents 1 and 2 1 1989 AIR 1607 6 submits that petitioner has no right to comment on any other students' ongoing admission process. The percentile scores of Mr. Ehteshamaul Haque and one Prasanna Rathi narrated in petitioner's affidavit are accurate, both of them secured more than 93.5 percentile in DILR; Mr. Ehteshamaul Haque secured 95.4 Percentile and Mr. Prasanna Rathi secured 96.3 and both of them cleared the actual section-wise overall percentile cut- offs, petitioner cannot claim parity with them. It is argued that there is no obligation on IIM, Mumbai to publish a list of candidates provisionally selected for Stage-II i.e. Personal Interview. Petitioner is attempting to gain a backdoor entry into Stage-II vide the present Writ Petition. Hence, it is prayed that this Writ Petition be dismissed. Learned counsel relies upon the judgment of the Hon'ble Kerala High Court in Shiny George Ambat v. Union of India (WP(C) No. 25484 of 2017) which laid rest to the question as to whether IIM specially IIM, Kozhikode would qualify as a 'State'. In view of the said judgment, it is argued that even IIM, Mumbai was designed to be an autonomous institution to be free from deep and pervasive State control so as to bring the affairs of the institution within the ambit of Article 12.
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6. From a perusal of the material on record, it is evident that petitioner's primary contention is founded on the premise that securing a high overall percentile of 99.52 in CAT- 2025 entitles him to be shortlisted for Stage-II process. However, it is to be seen, the Admission Policy for MBA Programme (Batch 2026-28), as specifically pleaded by the respondents, clearly provides through its proviso that the actual sectional and overall percentile cut-offs may be higher than the minimum prescribed thresholds depending upon the number of candidates to be shortlisted. Therefore, mere satisfaction of minimum eligibility criteria does not confer any enforceable right to be called for Personal Interview.
7. Petitioner, on his own, pleads that he secured 92.87 percentile in Data Interpretation & Logical Reasoning (DI&LR), whereas respondents have categorically pleaded, undisputedly and there is no effective rebuttal, that section-wise cut-off for General (Male) category was fixed at 93.50 percentile. Once it is established that petitioner did not meet the sectional cut-off, his candidature stood excluded at Stage-I itself. The Court cannot substitute or dilute such academic standards fixed by an expert body.
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8. Though petitioner attempts to compare with other candidates, namely Mr. Ehteshamaul Haque and Mr. Prasanna Rathi, respondents have specifically demonstrated that both candidates secured 95.4 and 96.3 percentile respectively in DI&LR, which is above the prescribed cut-off of 93.50 percentile. Thus, the plea of discrimination is factually untenable. Equality clause cannot be invoked in absence of similarity of circumstances.
9. Further, petitioner's argument that respondents failed to respond to his e mails dated 20.01.2026 and 21.01.2026 does not create any legal right. Admission processes involving large number of candidates do not impose an obligation on the institution to individually correspond with each unsuccessful applicant. Absence of communication does not vitiate a decision that is otherwise taken strictly in accordance with notified policy. Respondents have also justified enhancement of cut-offs on the ground of large number of applications. This is a reasonable and rational basis. Fixation of cut-offs is within the exclusive domain of academic authorities, and unless shown to be mala fide or in violation of statutory provisions, such decisions are not amenable to 9 judicial review. No such illegality is demonstrated in the present case.
10. Now coming to the issue of maintainability, though arguments are raised regarding Article 12 and territorial jurisdiction, even assuming the writ petition is maintainable, the petitioner fails on merits. It is a settled principle that writ jurisdiction under Article 226 is discretionary and equitable, and relief cannot be granted where no legal right is established. The reliance placed by petitioner on Anandi Mukta Sadguru Shree Mukta does not advance his case, as the said judgment expands the scope of writ jurisdiction but does not dispense with the requirement of establishing violation of a legal or fundamental right. In the present case, no such violation is made out.
11. Conversely, respondents' reliance on Shiny George Ambat supports their contention regarding institutional autonomy, though this Court has examined the matter primarily on merits. In sum, petitioner seeks to convert a competitive selection process into a matter of right based on overall percentile, ignoring the mandatory requirement of sectional cut-offs. Such a claim is contrary to the Admission Policy and cannot be sustained. The decision of the 10 respondents is based on objective criteria, uniformly applied, and free from arbitrariness, in the opinion of this Court. Therefore, the Writ Petition is liable to be dismissed.
12. The Writ Petition is accordingly, dismissed. No costs.
13. Consequently, the miscellaneous Applications, if any shall stand closed.
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NAGESH BHEEMAPAKA, J 20th April 2026 ksld