Case Note & Summary
The petitioner, Sri Ketan Babankatkar, a resident of Japan, applied for admission to the Post Graduate Programme in Management (PGPM) 2020-22 at the Indian Institute of Management, Bangalore (IIM-B). He was selected and was required to pay the admission fee by a specified deadline. Due to the COVID-19 pandemic and his location in Japan, he faced difficulties in accessing banking services and requested an extension of the fee payment deadline via emails dated 21.05.2020, 26.05.2020, 29.05.2020, and 31.05.2020. However, IIM-B rejected his admission by an email communication dated 09.06.2020, citing late payment. The petitioner filed a writ petition under Articles 226 and 227 of the Constitution of India seeking to quash the rejection email and direct IIM-B to consider his admission on merit. The court noted that the petitioner had made repeated requests for extension due to the pandemic, which was a global crisis affecting normal life. The court found that the respondent's decision to reject the admission without considering the petitioner's representation was arbitrary and unreasonable. The court held that the delay in fee payment was not attributable to the petitioner's negligence but to circumstances beyond his control. Accordingly, the court quashed the email communication dated 09.06.2020 and directed IIM-B to consider the petitioner's case for admission under the General Merit Category based on inter-se merit, as if the fee payment was made in time. The petition was allowed.
Headnote
A) Administrative Law - Arbitrariness - Fee Payment Deadline - The court examined whether the rejection of admission due to late fee payment was arbitrary in the context of the COVID-19 pandemic - Held that the respondent's decision to reject the petitioner's admission without considering his request for extension was arbitrary and unreasonable, as the pandemic had disrupted normal banking and communication channels (Paras 1-5). B) Education Law - Admission Policy - Extension of Time - The court considered the petitioner's request for extension of fee payment deadline due to his inability to access banking services from Japan during the pandemic - Held that the respondent should have considered the petitioner's representation and granted a reasonable extension, as the delay was not due to the petitioner's fault but due to circumstances beyond his control (Paras 3-5). C) Constitutional Law - Articles 226 and 227 of the Constitution of India - Writ Jurisdiction - The court exercised its writ jurisdiction to quash the email communication dated 09.06.2020 rejecting the petitioner's admission and directed the respondent to consider the petitioner's case for admission on merit - Held that the writ petition was maintainable as the respondent's action was arbitrary and violated principles of natural justice (Paras 1-5).
Issue of Consideration
Whether the rejection of the petitioner's admission to the Post Graduate Programme in Management (PGPM) 2020-22 at IIM Bangalore on the ground of late payment of fees, in the context of the COVID-19 pandemic and the petitioner's location in Japan, was arbitrary and illegal.
Final Decision
The court quashed the email communication dated 09.06.2020 issued by Respondent No.2 and directed Respondent No.2 to consider the case of the petitioner for admission in the Post Graduate Programme in Management (PGPM) 2020-22 under General Merit Category based on inter-se merit, as if the fee payment was made in time.
Law Points
- Writ of Certiorari
- Writ of Mandamus
- Arbitrariness
- Administrative Law
- Education Law
- Admission Policy
- Fee Payment Deadline
- COVID-19 Pandemic
- Natural Justice
- Reasonableness
