Case Note & Summary
The petitioners, Dekavadiya Nirupaben Bhavanjibhai and others, filed a Special Civil Application under Article 226 of the Constitution before the Gujarat High Court seeking a writ of mandamus. They prayed that the State Government and respondent authorities recognize the degrees of students who completed graduation and post-graduation from colleges affiliated with respondent No.5, SNDT University, for the purpose of recruitment to various posts by state agencies. The petitioners also sought interim directions during ongoing and future recruitment processes. The matter came before Justice Nirzar S. Desai. At the hearing, learned advocate Mr. Y.N. Ravani for the petitioners submitted that the issue was squarely covered by a decision dated 30.1.2020 of a coordinate Bench in Divya Dhirajlal Joshi v. State of Gujarat and others (Special Civil Application No. 18932/2017). The court noted that the petitioners' advocate conceded the coverage. Consequently, the court dismissed the petition in light of the said decision, without expressing any opinion on merits. The civil application for direction also stood disposed of. The judgment was delivered on 04/02/2026.
Headnote
A) Education Law - Recognition of Degrees - State Recruitment - The petitioners sought a writ of mandamus directing the State to recognize degrees from colleges affiliated with SNDT University for recruitment. The court held that the issue was squarely covered by a coordinate Bench decision in Divya Dhirajlal Joshi v. State of Gujarat, dated 30.1.2020, and dismissed the petition in light of that decision. (Para 2-3)
Issue of Consideration
Whether the degrees awarded by colleges affiliated with SNDT University should be recognized by the State of Gujarat for recruitment purposes.
Final Decision
The petition is dismissed in light of the decision dated 30.1.2020 of the coordinate Bench in Divya Dhirajlal Joshi v. State of Gujarat and others. The civil application for direction also stands disposed of.
Law Points
- Recognition of degrees
- University affiliation
- State recruitment
- Binding precedent
- Dismissal as covered
Case Details
2026 LawText (GUJ) (02) 37
R/SPECIAL CIVIL APPLICATION NO.18932 of 2017 with CIVIL APPLICATION (FOR DIRECTION) NO.1 of 2018
Mr. Y.N. Ravani for the Petitioners, Ms. Devanshi Patel, AGP for Respondent Nos.1 to 4, Mr. Bhushan B. Oza for Respondent No.5
Dekavadiya Nirupaben Bhavanjibhai & Ors.
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Nature of Litigation
Writ petition under Article 226 seeking mandamus for recognition of degrees from SNDT University affiliated colleges for state recruitment.
Remedy Sought
Petitioners sought a writ of mandamus directing the State Government and respondent authorities to recognize degrees of students who passed from colleges affiliated with SNDT University for recruitment purposes.
Filing Reason
The petitioners' degrees from SNDT University affiliated colleges were not being recognized by the State of Gujarat for recruitment to various posts.
Previous Decisions
The issue was covered by a coordinate Bench decision dated 30.1.2020 in Divya Dhirajlal Joshi v. State of Gujarat and others.
Issues
Whether the degrees awarded by colleges affiliated with SNDT University should be recognized by the State of Gujarat for recruitment purposes.
Submissions/Arguments
Learned advocate Mr. Y.N. Ravani for the petitioners submitted that the issue is squarely covered by the decision dated 30.1.2020 of a coordinate Bench in Divya Dhirajlal Joshi v. State of Gujarat and others.
Ratio Decidendi
The court dismissed the petition as the issue was squarely covered by a prior coordinate Bench decision, without expressing any opinion on merits.
Judgment Excerpts
Learned advocate Mr. Y. N. Ravani states that the issue involved in this petition is squarely covered by decision dated 30.1.2020 of coordinate Bench of this Court in the case of Divya Dhirajlal Joshi v. State of Gujarat and others, Special Civil Application No. 18932/2017.
In view of the aforesaid submission, the petition is dismissed in light of the decision dated 30.1.2020 of the coordinate Bench in the case of Divya Dhirajlal Joshi (supra).
Procedural History
The petition was filed in 2017. At the hearing on 04/02/2026, the petitioners' advocate submitted that the issue was covered by a 2020 decision. The court dismissed the petition accordingly.
Acts & Sections
- Constitution of India: Article 226