In a significant judgment, the Punjab and Haryana High Court quashed the expulsion of a law student from a prestigious educational institution, holding the disciplinary action unlawful and imposing a fine of ₹1 lakh on the institution for procedural lapses and violation of natural justice.
Justice Jasgurpreet Singh Puri, presiding over the case, emphasized that punishment must align with the principles of fairness and institutional regulations. The court reprimanded the institution for its arbitrary actions, stating that “disciplinary measures cannot override due process and established rules.”
The Case Background
The petitioner, Mr. Deepam Anand Singh, a student enrolled in the integrated law program (2023-28 batch), faced a series of disciplinary actions during his first year. Initial penalties included expulsion from hostel facilities and fines for alleged public misconduct and attendance malpractice. Matters escalated when the student was expelled from the program on allegations of unauthorized stay in the hostel.
The petitioner contested the expulsion, asserting that his three-day hostel stay was necessitated by a medical emergency—a burn injury that impeded his ability to travel. His appeals within the institution were dismissed without proper hearings, prompting him to seek judicial intervention through a writ petition (CWP-18689-2024).
Key Legal Issues
1. Violation of Institutional Regulations: The expulsion order was issued by the Hostel and Student Affairs (HSA) Committee, which lacked jurisdiction under the institution’s Academic Handbook. The designated disciplinary authority for campus conduct was the Integrated Program in Law (IPL) Committee.
2. Double Jeopardy: The court found that earlier penalties served as the foundation for subsequent punishments, constituting “double jeopardy,” which is impermissible under law.
3. Denial of Natural Justice: The appellate authority (institution’s Director) treated the petitioner’s appeal as a “mercy plea” without granting a hearing or providing reasoned deliberation.
Court’s Observations and Decision
The court deemed the institution’s actions procedurally flawed and devoid of legal authority. Justice Puri observed, “Punishment cannot be layered upon punishment already served. Such actions undermine the principles of natural justice and institutional accountability.”
The court quashed the expulsion order, setting aside prior disciplinary actions that violated the institution’s regulations. Additionally, it ruled that the petitioner’s semester results must be declared, allowing him to resume his studies without repeating the academic year or incurring additional fees.
₹1 Lakh Fine and Directions for Accountability
Acknowledging the adverse impact on the petitioner’s academic career, the court imposed a fine of ₹1 lakh on the institution. The amount, payable within three months, was intended to compensate for the undue hardship caused by arbitrary actions. The court further directed the institution’s Board of Governors to identify and hold accountable those responsible for procedural lapses, including potential recovery of the fine from errant officials.
Advocate Priyanka Sud represented the petitioner, while Advocate Vivek Singla appeared for the respondents.
