Supreme Court Orders IIT Admission for Marginalized Student After Technical Glitch: Atul Kumar vs. Joint Seat Allocation Authority (2024) INSC 749 (30 September 2024)

Introduction

Date of the Judgment: 30 September 2024
Citation: 2024 INSC 749
Judges: Dr Dhananjaya Y Chandrachud, CJI, J B Pardiwala, J, Manoj Misra, J

Can a technical error prevent a deserving student from securing admission to a prestigious institution? The Supreme Court of India recently addressed this critical question in a case involving a student from a marginalized community who faced denial of admission to an Indian Institute of Technology (IIT) due to an online payment processing issue. The Court, exercising its powers under Article 142 of the Constitution, ensured that the student was granted admission, emphasizing the importance of substantial justice. This case highlights the judiciary’s role in protecting the rights of marginalized students and ensuring equal access to education.

Case Background

Atul Kumar, the petitioner, is a meritorious student belonging to the Scheduled Caste category. He appeared for the JEE (Advanced) 2024 examination and secured a rank of 1455 in his category. He was allotted a seat at the Indian Institute of Technology Dhanbad for a four-year Bachelor of Technology course in Electrical Engineering. This was his second and final attempt to secure admission. Atul’s father is a daily wager, and the family’s income is below the poverty line. He completed his higher secondary education from Khatauli, District Muzaffarnagar, Uttar Pradesh.

The deadline for online reporting, including fee payment and document upload, was 5 pm on June 24, 2024. Atul’s parents arranged the required funds, and the fees were deposited into his brother’s account by 4:45 pm. Atul logged into the first respondent’s portal at 4:45 pm, applied in the ‘float category,’ and uploaded his documents. However, the portal closed at 5 pm, and his payment was not processed.

Timeline

Course of Proceedings

The petitioner initially approached the Jharkhand High Court Legal Aid Service Committee, which directed him to the Legal Services Committee of the Madras High Court. A writ petition was filed in the High Court of Madras, but during the hearing, the petitioner was advised to approach the Supreme Court of India.

Legal Framework

The Supreme Court invoked its power under Article 142 of the Constitution of India to ensure “substantial justice.” Article 142 empowers the Supreme Court to pass any order necessary to do complete justice in any case pending before it. This provision allows the Court to go beyond the strict letter of the law to address unique situations where justice might otherwise be denied.

Arguments

The petitioner argued that he had taken all necessary steps to secure his admission, including arranging funds and logging into the portal within the stipulated time. The only reason for his non-admission was a technical glitch in the online payment system, which was beyond his control. He emphasized his meritorious performance and marginalized background, highlighting the injustice of denying him admission.

The respondent acknowledged that the petitioner had diligently accessed the portal multiple times and had made earnest efforts to complete the admission process. The login details provided by the first respondent confirmed the petitioner’s efforts to log into the portal on June 24, 2024, between 15:12 hours and 16:57 hours, on six occasions.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues but addressed the core issue of whether the petitioner should be denied admission due to a technical glitch, despite fulfilling all other requirements.

Treatment of the Issue by the Court

Authorities

The Supreme Court primarily relied on its inherent power under Article 142 of the Constitution of India to do complete justice. There were no other cases or legal provisions cited in this judgment.

Judgment

The Court did not rely on any specific authorities other than Article 142 of the Constitution of India.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the following factors: the petitioner’s meritorious performance, his marginalized background, and his diligent efforts to complete the admission process. The Court emphasized that a technical glitch should not deprive a deserving student of his rightful opportunity to pursue higher education. The Court’s decision was driven by a commitment to ensuring substantial justice and protecting the rights of marginalized communities.

The Court’s reasoning was based on the principle of substantial justice. It noted that the petitioner had done everything within his power to secure admission and that denying him admission due to a technical glitch would be unjust. The Court stated, “A talented student like the petitioner who belongs to a marginalized group of citizens and has done everything to secure admission should not be left in the lurch.” The Court also emphasized its power under Article 142 of the Constitution to cover such situations.

The Court considered the possibility of denying admission but rejected it, stating that it would be a grave injustice. The Court decided to create a supernumerary seat, if necessary, to accommodate the petitioner without disturbing any existing student. The Court also ordered that the petitioner be given all consequential benefits of admission, including hostel accommodation and other facilities. The Court noted, “The power of this Court under Article 142 of the Constitution to do substantial justice is meant precisely to cover such a situation.”

The Court directed that the petitioner be admitted to the same batch to which he would have been admitted originally. It also requested the Director of IIT Dhanbad to ensure that the petitioner can complete the course work for the period that has already elapsed. The Court observed, “Since the admission of the petitioner has been delayed for no fault of his, we request the Director of IIT Dhanbad to use his good offices to ensure that the petitioner can duly complete the course work for the period which has already elapsed during this academic year.”

Key Takeaways

• ✓ The Supreme Court can use its power under Article 142 of the Constitution to ensure substantial justice in unique cases.
• ✓ Technical glitches should not be a barrier to education for deserving students, especially those from marginalized communities.
• ✓ Educational institutions must have robust systems in place to prevent technical errors from affecting students’ admission processes.
• ✓ The Court’s decision highlights the importance of ensuring equal access to education for all, regardless of their background.

Directions

The Supreme Court directed that:

• ✓ The petitioner should be granted admission to IIT Dhanbad against the seat allotted to him in Electrical Engineering.
• ✓ The petitioner should be admitted to the same batch to which he would have been admitted originally.
• ✓ A supernumerary seat shall be created for the petitioner, if required, without disturbing any existing student.
• ✓ The petitioner would be entitled to all consequential benefits of admission, including hostel accommodation and other facilities.
• ✓ The Director of IIT Dhanbad should ensure that the petitioner can complete the course work for the period that has already elapsed.

Specific Amendments Analysis

Not applicable in this case.

Development of Law

The ratio decidendi of this case is that the Supreme Court can invoke Article 142 of the Constitution to do complete justice, particularly in cases involving marginalized students facing technical issues that hinder their access to education. This case reinforces the principle that technicalities should not override the pursuit of justice and equal opportunity, especially for those from disadvantaged backgrounds.

Conclusion

The Supreme Court’s judgment in the case of Atul Kumar vs. The Chairman (Joint Seat Allocation Authority) and Others is a significant step towards ensuring that deserving students from marginalized backgrounds are not denied opportunities due to technical glitches. By invoking its powers under Article 142 of the Constitution, the Court has not only provided justice to the petitioner but also set a precedent for future cases where technicalities might hinder the pursuit of education. This case underscores the judiciary’s role in upholding the principles of equity and social justice in the education sector.