The Supreme Court has held that a university’s failure to include a bona fide student’s name in its admission disclosure list cannot justify withholding verification of his academic credentials when the records establish that he was validly admitted and passed the course.
Granting relief to a Jammu and Kashmir State Taxes Department employee whose appointment remained subject to verification of his degree, the bench of Justices Vikram Nath, Augustine George Masih and Sandeep Mehta directed Manav Bharti University to issue corrected marks certificates and forward the verification report to his employer within three weeks. It further stated that the employer was expected to release outstanding salary and consequential benefits within four weeks of receiving the verification.
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The case concerned Mohd. Asad Choudhary, who pursued a B.Tech in Civil Engineering at Manav Bharti University during the academic session 2014–2018. The university issued detailed marks certificates for all eight semesters, along with bonafide, migration and character certificates. His degree, dated October 15, 2018, recorded that he had passed the examination held in May 2018 in the first division.
After completing the course, Choudhary was appointed as a Sub-Inspector in the State Taxes Department, Jammu and Kashmir. His employer sought verification of his degree through communications issued in May 2022, September 2023 and December 2023. A further letter issued in July 2024 recorded that the verification report remained pending and that his appointment was subject to verification of his academic certificates.
Meanwhile, allegations concerning the sale of degrees by the university led to the registration of criminal cases against its former administration. The Special Investigation Team seized university records, leaving students unable to obtain their academic documents.
A letter addressed by students to the Chief Justice of the Himachal Pradesh High Court in April 2022 resulted in the registration of a public interest litigation. Individual petitions, including Choudhary’s, were subsequently considered alongside it.
Pursuant to an order of the High Court, the Himachal Pradesh Government constituted a Document Verification Committee in August 2022 under the chairmanship of the Superintendent of Police, Solan. Its members included the university’s Administrator and the Secretary of the Himachal Pradesh Private Educational Institutions Regulatory Commission, or HP-PERC.
The university confirmed in July 2024 that Choudhary had been enrolled against allotted seats in an approved course. His name appeared in the Green Sheet and examination records, and there was no dispute concerning the year of his admission and registration.
However, his name had not been included in the admission disclosure list sent to HP-PERC and was absent from the approved list. Verification was also obstructed by differences between the marks recorded in the result gazette and those appearing in the Green Sheet and detailed marks certificates for his seventh and eighth semesters.
The High Court disposed of the connected proceedings on December 20, 2024, observing that it could not determine the disputed questions and leaving the students free to approach the competent court. Choudhary challenged that decision before the Supreme Court.
Before the Supreme Court, Choudhary argued that he had completed the course, passed every semester examination and received his degree. He maintained that the university’s omission of his name from the admission disclosure list was beyond his control and could not be used to penalise him.
He also submitted that he had continued working without receiving salary because his academic credentials had not been verified. Requiring him to initiate fresh proceedings after the public interest litigation had remained pending for more than two years would, he argued, be burdensome and inequitable.
In its counter affidavit, the university acknowledged that he had secured admission against allotted seats, cleared all eight semesters and received the corresponding marks certificates. It also confirmed that his name appeared in its Green Sheet Register, which it described as its primary internal record.
The university attributed his exclusion from the admission disclosure list to a clerical and inadvertent human error by its previous administration.
The Supreme Court examined an inconsistency in the university’s explanation. While one part of its affidavit attributed the missing admission entry to a clerical error, another suggested that the student’s data could not be sent to HP-PERC because of the mismatch in marks.
The Court noted that the admission disclosure list related to the 2014–2015 session, whereas the disputed marks concerned examinations held in December 2017 and May 2018. The later discrepancy therefore could not explain the earlier omission.
Accepting the university’s admission of clerical error, the Bench found that the documents and affidavits established Choudhary’s status as a bona fide student who had been admitted against an allotted seat and passed all his examinations.
“Such a lapse cannot be visited with adverse consequences upon the Appellant,” the Court observed. It held that the omission could not justify withholding verification of his academic credentials.
On the mismatch in marks, the Court found that both sets of university records showed Choudhary as having passed the seventh and eighth semesters. None of the respondents suggested otherwise.
The discrepancy consequently did not affect the validity of his admission, his status as a student or the fact that he had completed the course. The Bench concluded that he had validly passed all examinations and was entitled to the degree conferred upon him.
The only remaining question was which set of figures correctly reflected the marks obtained in the two semesters. The Court held that this required verification of the university’s own result records, rather than evidence that the student could independently produce.
The verification committee had submitted that its role was confined to verification and supply of documents, that it held photocopies while original records were with trial courts, and that it had no authority to create, alter or correct university documents. The Court nevertheless found that checking the existing result records fell within the verification responsibility entrusted to it.
The Bench held that no factual dispute remained concerning Choudhary’s completion of the examinations and acquisition of his degree. Sending him to another court merely to resolve the limited question of his correct marks was therefore unwarranted.
It set aside the High Court’s December 2024 order insofar as it concerned Choudhary.
The State was directed to provide the university with the seventh and eighth semester result records available with the verification committee. Based on those records, the university must issue corrected detailed marks certificates and any other consequential documents.
The university must also forward the academic verification report to the Additional Commissioner, State Taxes (Administration and Enforcement), Kashmir, within three weeks of the judgment.
Upon receipt of the verification, the employer is expected to release all salary arrears due to Choudhary, together with consequential benefits, within a further four weeks.
The appeal was allowed without any order as to costs. The relief rests on the established facts of Choudhary’s admission and successful completion of the course; the Court did not extend its order to all students involved in the connected proceedings.
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