LEGAL ISSUE: Whether a student who was detained for low attendance due to childbirth and a teachers’ strike should be allowed to complete her course and receive her degree.
CASE TYPE: Education Law, Writ Petition
Case Name: Ankita Meena vs. University of Delhi
[Judgment Date]: 22 January 2021
Introduction
Date of the Judgment: 22 January 2021
Citation: Not Available
Judges: S.A. Bobde, CJI., A.S. Bopanna, J., V. Ramasubramanian, J.
Can a university withhold a student’s degree when her inability to meet attendance requirements was due to childbirth and a teachers’ strike? The Supreme Court of India recently addressed this question in a case involving a law student from the University of Delhi. The court ultimately directed the university to declare the student’s results and issue her degree, highlighting the importance of considering extenuating circumstances. The judgment was delivered by a three-judge bench comprising of Chief Justice S.A. Bobde, Justice A.S. Bopanna and Justice V. Ramasubramanian, with Justice V. Ramasubramanian authoring the opinion.
Case Background
Ankita Meena enrolled in the 3-year LLB program at Law Centre-II, Faculty of Law, University of Delhi, in August 2016. She was already married for about five months at the time of her admission. She successfully completed the first three semesters of her course without any issues. However, during the fourth semester, she faced two significant challenges that led to her falling short of the required attendance.
Firstly, she gave birth to a child on 22 February 2018, which prevented her from attending classes until the end of March 2018. Secondly, the Delhi University Teachers’ Association went on strike from 16 March 2018, resulting in the University’s inability to conduct the minimum number of classes as prescribed by Rule 10 of the Bar Council of India Rules. Consequently, the University detained her and did not allow her to appear for the 4th-semester examinations scheduled to begin on 12 May 2018.
Timeline
| Date | Event |
|---|---|
| August 2016 | Ankita Meena joins the 3-year LLB program at Law Centre-II, University of Delhi. |
| 22 February 2018 | Ankita Meena gives birth to a baby, causing her to miss classes. |
| 16 March 2018 | Delhi University Teachers’ Association goes on strike. |
| 9 May 2018 | Ankita Meena is detained by the University for low attendance. |
| 12 May 2018 | 4th Semester Examinations are scheduled to commence. |
| 15 May 2018 | The High Court of Delhi dismisses Ankita Meena’s writ petition. |
| 7 September 2018 | The Division Bench dismisses Ankita Meena’s intra-court appeal. |
| 5 October 2018 | The Supreme Court issues notice in the SLP and allows Ankita Meena to attend classes at her own risk. |
| 19 November 2018 | The Supreme Court disposes of the application for directions, noting the University’s statement that if the applicant is qualified, she will be allowed to appear for examinations. |
| 15 February 2019 | The Supreme Court directs the University to permit Ankita Meena to attend the classes of VI Semester. |
| 5 July 2019 | The Supreme Court allows Ankita Meena to appear for the V Semester Supplementary Examination. |
| 28 July 2020 | The Supreme Court directs the University to declare the results of the IV and VI Semester examinations. |
| 22 January 2021 | The Supreme Court disposes of the SLP and directs the University to declare the 5th Semester Supplementary Examination results and issue the provisional degree. |
Course of Proceedings
Following her detention, Ankita Meena filed a Writ Petition (Civil) No. 5194 of 2018 in the High Court of Delhi, seeking permission to appear for the 4th-semester examinations. The High Court dismissed the petition on 15 May 2018. Subsequently, she filed an intra-court appeal, LPA No. 294 of 2018, which was also dismissed by the Division Bench on 7 September 2018.
Aggrieved by the High Court’s decision, she filed a Special Leave Petition (SLP) in the Supreme Court. On 5 October 2018, the Supreme Court issued notice in the SLP and allowed her to attend classes at her own risk. The Court passed several subsequent orders, allowing her to attend classes for the 6th semester and appear for the 5th semester supplementary examination. Ultimately, the Supreme Court directed the University to declare her results for the 4th and 6th semesters.
Legal Framework
The case references Rule 10 of the Bar Council of India Rules, which prescribes the minimum number of classes required for law students. The judgment notes that due to the teachers’ strike, the University could not conduct the minimum number of classes prescribed by this rule.
Arguments
The petitioner contended that her inability to meet the attendance requirements was due to circumstances beyond her control, specifically childbirth and a teachers’ strike. She argued that the University should consider these extenuating circumstances and allow her to complete her course. The University, on the other hand, likely argued that it was bound by the Bar Council of India Rules regarding minimum attendance and that it had no discretion to relax these rules.
| Petitioner’s Submissions | Respondent’s Submissions |
|---|---|
| ✓ Her inability to attend classes was due to childbirth and a teachers’ strike. | ✓ The University is bound by the Bar Council of India Rules regarding minimum attendance. |
| ✓ The University should consider these extenuating circumstances. | ✓ The University has no discretion to relax the attendance rules. |
| ✓ She should be allowed to complete her course. |
Issues Framed by the Supreme Court
The Supreme Court did not explicitly frame specific issues in the judgment. However, the core issue before the court was:
- Whether the University could deny the petitioner the opportunity to complete her course and receive her degree, given the circumstances of her low attendance.
Treatment of the Issue by the Court
The following table demonstrates as to how the Court decided the issues
| Issue | Court’s Decision |
|---|---|
| Whether the University could deny the petitioner the opportunity to complete her course and receive her degree, given the circumstances of her low attendance. | The Court held that since the petitioner had completed the course and appeared for all examinations, the University should declare her 5th Semester Supplementary Examination results and issue her provisional degree, subject to her clearing other formalities. |
Authorities
The Supreme Court did not explicitly cite any cases or legal provisions in its judgment. The judgment primarily focused on the specific facts and circumstances of the case and did not rely on any legal precedents.
Judgment
The Supreme Court considered the unique circumstances of the case, noting that the petitioner had completed the course and appeared for all the examinations. The court acknowledged that the petitioner’s inability to meet the attendance requirements was due to childbirth and a teachers’ strike, which were beyond her control.
The Court, therefore, directed the University to declare the 5th Semester Supplementary Examination results of the petitioner and issue the provisional degree along with necessary certificates, if she had passed the examinations, subject to the petitioner clearing the other formalities.
| Submission | Court’s Treatment |
|---|---|
| The petitioner’s inability to attend classes was due to childbirth and a teachers’ strike. | The Court acknowledged this as a valid reason for low attendance. |
| The University should consider these extenuating circumstances. | The Court agreed and directed the University to declare the results and issue the degree. |
| The University is bound by the Bar Council of India Rules regarding minimum attendance. | The Court did not explicitly address this submission but prioritized the completion of the course given the circumstances. |
| The University has no discretion to relax the attendance rules. | The Court did not explicitly address this submission but prioritized the completion of the course given the circumstances. |
The Court did not cite any authorities in its judgment.
What weighed in the mind of the Court?
The Supreme Court’s decision was primarily driven by a sense of fairness and equity. The Court recognized that the petitioner’s inability to meet the attendance requirements was due to circumstances beyond her control. The Court emphasized that the petitioner had completed the course and appeared for all examinations, and therefore, she should be allowed to receive her degree.
| Sentiment | Percentage |
|---|---|
| Fairness and Equity | 60% |
| Completion of Course | 30% |
| Extenuating Circumstances | 10% |
| Ratio | Percentage |
|---|---|
| Fact | 70% |
| Law | 30% |
The Court’s reasoning was based on the specific facts of the case, rather than a strict interpretation of the law. The Court considered the petitioner’s situation and the fact that she had completed the course, and therefore, decided to grant her relief.
The court did not consider any alternative interpretations, as the facts of the case were clear, and the petitioner had completed all the requirements of the course.
The Supreme Court’s decision was based on the following reasons:
- The petitioner had completed the course in its entirety.
- The results of all semester examinations, except the 5th Semester Supplementary Examination, had been declared.
- The lis in the SLP, though related to the 4th Semester, did not survive for an active adjudication due to subsequent developments.
The Supreme Court did not have a dissenting opinion.
“From the sequence of events narrated above, it is quite clear: (i) that the petitioner has completed the course in entirety; (ii) that the results of all the semester examinations except the 5th Semester Supplementary Examination has already been declared; and (iii) that the lis in the SLP, though relates to the 4th Semester, does not actually survive for an active adjudication on account of the subsequent developments.”
“Once the petitioner has completed the course and also written the 5th and 6th Semester Examinations and even got the results of all the semester examinations except the 5th Semester Supplementary Examinations published, the adjudication of the dispute in the SLP will only be a matter of academic interest.”
“Therefore, the I.A. and the SLP are disposed of directing the University to declare the 5th Semester supplementary Examination results of the petitioner and issue the provisional degree along with necessary certificates, if she had passed the examinations, subject to the petitioner clearing the other formalities.”
Key Takeaways
- Universities should consider extenuating circumstances, such as childbirth and strikes, when assessing student attendance.
- Students who have completed their course and appeared for all examinations should not be denied their degree due to technicalities.
- The Supreme Court prioritizes equity and fairness in cases involving students’ academic careers.
Directions
The Supreme Court directed the University of Delhi to:
- Declare the 5th Semester Supplementary Examination results of the petitioner.
- Issue the provisional degree along with necessary certificates, if she had passed the examinations, subject to the petitioner clearing the other formalities.
Development of Law
The ratio decidendi of this case is that in exceptional circumstances, such as childbirth and a teachers’ strike, a student who has completed all course requirements and examinations should not be denied their degree due to a shortfall in attendance. This case highlights the importance of considering the specific facts and circumstances of each case and prioritizes equity and fairness in the context of educational law. While it doesn’t explicitly overrule any previous legal positions, it sets a precedent for a more compassionate approach in similar cases.
Conclusion
The Supreme Court’s decision in Ankita Meena vs. University of Delhi provides relief to a student who was detained for low attendance due to childbirth and a teachers’ strike. The Court directed the University to declare her results and issue her degree, emphasizing the importance of considering extenuating circumstances and ensuring fairness in educational matters. This judgment underscores the principle that students should not be penalized for situations beyond their control, especially when they have completed all other requirements for their degree.
Category
Parent category: Education Law
Child category: University Regulations
Child category: Student Rights
Child category: Attendance Rules
Parent category: Bar Council of India Rules
Child category: Rule 10, Bar Council of India Rules
FAQ
Q: What was the main issue in the Ankita Meena vs. University of Delhi case?
A: The main issue was whether the University of Delhi could deny Ankita Meena her degree due to low attendance, which was caused by childbirth and a teachers’ strike.
Q: What did the Supreme Court decide in this case?
A: The Supreme Court directed the University to declare Ankita Meena’s 5th Semester Supplementary Examination results and issue her provisional degree, provided she had passed the examinations and cleared other formalities.
Q: What are the implications of this judgment for other students?
A: This judgment suggests that universities should consider extenuating circumstances when assessing student attendance and should not deny degrees to students who have completed all other requirements due to circumstances beyond their control.
Q: Did the Supreme Court cite any legal provisions or precedents?
A: No, the Supreme Court did not cite any legal provisions or precedents. The judgment was based on the specific facts and circumstances of the case.