Case Note & Summary
The petitioner, Prathmesh S/o Ganesh Pedamkar, a Scheduled Caste candidate with a B.E. in Mechanical Engineering, sought admission to the M.Des. course at IIT Bombay for the academic year 2020-21. He appeared for the Common Entrance Examination on January 18, 2020, and the results were declared on March 4, 2020. He cleared the examination and was called for an online interview. By emails dated March 16, 2020, and May 15, 2020, the IIT confirmed his registration and receipt of fees. On July 7, 2020, he was shortlisted for an online interview and asked to submit his portfolio. The interview was conducted between July 21 and 26, 2020. On July 31, 2020, the IIT declared the first list of admitted candidates, which included the petitioner's name. However, on August 7, 2020, the IIT sent an email withdrawing the admission offer on the ground that the petitioner had not submitted his caste certificate within the stipulated time. The petitioner had submitted his caste certificate on August 5, 2020, after the deadline. The petitioner filed a writ petition challenging the withdrawal. The court held that the IIT's action was arbitrary and violative of Article 14 of the Constitution. The court noted that the petitioner had been selected on merit, had paid fees, and had been issued an admission offer. The requirement to submit the caste certificate within a specified time was directory, not mandatory, and the IIT could not withdraw the admission on such a technical ground. The court directed the IIT to admit the petitioner to the M.Des. course for the academic year 2020-21.
Headnote
A) Constitutional Law - Right to Equality - Arbitrariness - Article 14 of the Constitution of India - Denial of admission to a Scheduled Caste candidate on the ground of delayed submission of caste certificate, despite the candidate having been selected on merit and having paid fees, is arbitrary and violative of Article 14. The court held that the IIT's action in withdrawing the admission offer was unreasonable and disproportionate. (Paras 1-14) B) Administrative Law - Legitimate Expectation - Admission to Educational Institutions - A candidate who has been selected, paid fees, and issued an admission offer has a legitimate expectation that admission will not be withdrawn on technical grounds. The court held that the IIT's reservation of right to withdraw admission at any time cannot be exercised arbitrarily. (Paras 7-14) C) Reservation - Scheduled Caste - Caste Certificate - Time Limit for Submission - The requirement to submit a caste certificate within a specified time is directory, not mandatory, especially when the candidate belongs to a reserved category and the certificate is subsequently verified. The court directed the IIT to admit the petitioner. (Paras 10-14)
Issue of Consideration
Whether the denial of admission to the petitioner, a Scheduled Caste candidate, to the M.Des. course at IIT Bombay on the ground that he failed to submit his caste certificate within the stipulated time is arbitrary and violative of Article 14 of the Constitution.
Final Decision
The court allowed the writ petition and directed the IIT Bombay to admit the petitioner to the M.Des. course for the academic year 2020-21, holding that the withdrawal of admission was arbitrary and violative of Article 14 of the Constitution.
Law Points
- Article 14 of the Constitution of India
- Right to equality
- Arbitrariness
- Admission to educational institutions
- Scheduled Caste reservation
- Caste certificate
- Time limit for submission of documents
- Estoppel
- Legitimate expectation
