Case Note & Summary
The dispute arose from a writ petition filed by the appellant challenging the validity of a Master of Engineering (M.E.) degree obtained by the ninth respondent, C.A. Seethalakshmi, a lecturer at a Government Polytechnic College. The appellant contended that the degree was not obtained as a regular student, but while she was in service, and thus sought to question its validity before the employer. The writ petition was instituted after a lapse of 19 years from the date the degree was granted by Anna University. The appellant did not produce any acceptable evidence before the employer to substantiate the claim; he merely relied on a presumption that the respondent was employed during the period she pursued the course. The respondents included the State of Tamil Nadu, educational authorities, and the degree holder. The core legal issue was whether a writ court could entertain such a belated challenge based on mere suspicion, in the absence of any admissible evidence. During the hearing, the court noted that evening colleges for M.E. degrees were approved by the All India Council for Technical Education (AICTE) and that Anna University itself had conducted such evening courses, which were treated as regular degree courses. The court held that it could not probe into the validity of the degree under these circumstances, where the appellant had failed to place any material before the employer to create a cause of action for further proceedings. The writ court had correctly dismissed the petition, and the appellate bench found no reason to interfere. Accordingly, the writ appeal was dismissed without costs, and the connected miscellaneous petition was closed. The decision reinforces the principle that writ jurisdiction is not meant to entertain stale claims unsupported by evidence, especially in matters of academic qualifications where public bodies like AICTE and Anna University have prescribed valid modes of instruction.
Headnote
A) Education Law – Validity of Degree – Evening M.E. Courses – Anna University, AICTE – Evening M.E. courses conducted by Anna University and approved by All India Council for Technical Education (AICTE) are regular degree courses. Challenge to such degree based on the holder being employed during the course period is not sustainable without acceptable evidence (Para 2-3). B) Writ Jurisdiction – Delay and Laches – Insufficient Evidence – Code of Civil Procedure, 1908 (not directly cited) – The High Court declined to entertain a writ petition filed after a lapse of 19 years from the date of passing of the degree, where the petitioner failed to produce any admissible evidence before the employer and relied solely on presumption that the degree holder was employed during the course. Held, writ petition was rightly dismissed; appeal dismissed (Para 2-4).
Issue of Consideration
Whether the writ court was correct in dismissing a writ petition that challenged the validity of a M.E. degree obtained 19 years earlier on the ground that the degree was obtained while the respondent was in service, in the absence of acceptable evidence.
Final Decision
The writ appeal is dismissed. No costs. Connected miscellaneous petition is closed.
Law Points
- Evening M.E. courses approved by AICTE and conducted by Anna University are regular degree courses
- writ jurisdiction cannot be invoked based on mere presumption without admissible evidence
- delay of 19 years in challenging degree validity is fatal
