The Supreme Court has directed Manav Bharti University to release the marksheets and degree of a law student, ruling that a student cannot be made to suffer for a “clerical and inadvertent error” committed by the University administration.
The Bench of Justice Vikram Nath and Justice Augustine George Masih set aside an order of the Himachal Pradesh High Court that had relegated the student to a competent court for factual adjudication. The Apex Court observed that since the University had admitted its mistake in the records, no factual dispute remained to be adjudicated.
Background of the Case
The appeal was filed by Pratima Das, a student of the BA.LLB batch of 2017-2022 at Manav Bharti University (MBU). She had approached the Supreme Court seeking the release of her marksheets for the 5th to 10th semesters and her law degree.
The controversy arose in the backdrop of an investigation against the University regarding the alleged sale of fake degrees. A First Information Report (FIR) was registered, and a Special Investigation Team (SIT) seized the University’s records in 2019. Consequently, students faced difficulties in procuring their academic documents.
To address these grievances, the Himachal Pradesh High Court had earlier directed the University to constitute a committee for document verification. The criteria included cross-referencing the “Green Register” (primary internal record) with the “Admission Disclosure List.”
The Discrepancy
When the Appellant sought her documents, she was informed that while her name appeared in the Green Register under Admission No. R17BALLB0033, it was missing from the Admission Disclosure List for the 2017-2018 session. Instead, the name of another student, “Mr. Ayaan Narwal,” was reflected against her admission number. Due to this mismatch, her documents were withheld.
The Appellant approached the High Court multiple times. In a Public Interest Litigation (CWPIL No. 22 of 2022), the High Court, vide an order dated December 20, 2024, disposed of the matter, observing that it could not determine disputed questions of fact and relegated the students to approach a competent court. Aggrieved by this delay and the relegation to civil remedies, the student moved the Supreme Court.
Arguments and University’s Admission
Before the Supreme Court, the counsel for the Appellant argued that she had cleared all semester examinations, and her name was duly reflected in the Green Sheet Register. It was submitted that the error in the Admission Disclosure List was not her fault, and the non-supply of documents had stalled her enrollment with the Bar Council and further education.
The crucial turn in the case came through an additional affidavit filed by the Registrar of Manav Bharti University on December 3, 2025.
In the affidavit, the University admitted that the Appellant was a bona fide student. The Registrar stated:
“However, due to a clerical and inadvertent human error, by the previous administration of the University Petitioner’s name was not included in the admission disclosure list sent to the HP-PERC, and instead, the name of one Mr. Ayaan Narwal was mistakenly forwarded.”
The University further clarified that Mr. Ayaan Narwal was a student of the 2016-2021 batch, and his inclusion in the Appellant’s slot was a “clerical mismatch” and not a deletion of the Appellant’s admission.
Court’s Observations and Decision
Taking note of the University’s affidavit, the Supreme Court held that the facts were now undisputed. The Bench observed:
“From the above affidavit and documents on record, it is undisputed that the Appellant has been a bona fide student of MB University and had cleared all her examinations. It is also evident that the exclusion of the name of the Appellant in the admission disclosure list has occurred due to no fault on part of the Appellant, rather the same is at the hands of the University for which the Appellant cannot be made to suffer.”
The Court further noted that relegating the student to another court, as directed by the High Court, was no longer required since the University had admitted the error.
“Having regard to the above established facts based on records, we are of the view that the Appellant has been deprived of her documents for no fault of hers for a substantial period of time…” the Court held.
Allowing the appeal, the Supreme Court directed Manav Bharti University to issue the marksheets of the 5th to 10th semesters, the degree, and any other relevant documents to the Appellant within four weeks.
Case Details:
- Case Title: Pratima Das vs. State of Himachal Pradesh and Ors.
- Case No.: Civil Appeal arising out of SLP (Civil) No. 15180 of 2025
- Bench: Justice Vikram Nath and Justice Augustine George Masih
