Case Note & Summary
The dispute arose from a writ petition filed by Soutrik Sarangi challenging Criterion No. 5 of the JEE (Advanced) Information Brochure, which prevented candidates who had been admitted to an IIT from appearing in subsequent JEE (Advanced) examinations. Soutrik had appeared in JEE (Main) 2020, qualified for JEE (Advanced) 2020, and secured admission to IIT Kharagpur in Chemical Engineering Dual Course. He wished to appear in JEE (Advanced) 2021 to improve his rank for a preferred course, but was barred by Criterion No. 5, which allowed candidates admitted to non-IIT institutions to reappear. He approached the Calcutta High Court, alleging arbitrariness and discrimination under Article 14. The Single Judge allowed his petition, holding the criterion discriminatory as it treated IIT-admitted candidates differently from non-IIT-admitted ones, despite both causing seat wastage, and directed IIT to reconsider and permit Soutrik to register for JEE (Advanced) pending decision. IIT appealed to the Supreme Court, justifying the criterion as based on public policy to avoid seat blockage and ensure equitable access, and arguing Soutrik's conduct estopped him. Soutrik contested maintainability, urging exhaustion of appellate remedies. The Supreme Court first overruled the maintainability objection, noting Article 136's flexibility and lack of earlier objection. On merits, the Court analyzed Criterion No. 5, finding it served legitimate objectives: preventing wastage of scarce IIT seats, which are highly competitive and limited, and ensuring candidates do not speculate by abandoning seats after admission. The Court held the distinction between IIT and non-IIT admissions is rational, as IITs have unique prestige and demand, and the criterion applies uniformly. It rejected the discrimination argument, stating the High Court erred in equating IIT and non-IIT seats without considering statutory rules and public interest. The Court set aside the High Court's judgment, upholding Criterion No. 5 as not arbitrary or unconstitutional, and dismissed Soutrik's challenge.
Headnote
A) Constitutional Law - Article 14 - Equality and Non-Discrimination - Constitution of India, 1950, Article 14 - Challenge to JEE (Advanced) eligibility criterion barring IIT-admitted candidates from subsequent attempts - Court held the criterion is not arbitrary as it serves legitimate public policy objectives of preventing seat wastage and ensuring equitable access, and does not violate Article 14 by distinguishing between IIT and non-IIT admissions based on rational classification (Paras 15-18). B) Civil Procedure - Supreme Court Jurisdiction - Article 136 Special Leave Petition - Constitution of India, 1950, Article 136 - Maintainability of direct appeal to Supreme Court bypassing High Court Division Bench - Court overruled objection, holding that exhaustion of appellate remedies is a rule of convenience, not immutable, and Article 136 discretion is wide to correct injustices, especially given interim orders and lack of earlier objection (Paras 13-14).
Issue of Consideration
Whether Criterion No. 5 of the JEE (Advanced) Information Brochure, which bars candidates who have been admitted to an IIT from appearing in subsequent JEE (Advanced) examinations, is arbitrary and discriminatory under Article 14 of the Constitution of India.
Final Decision
The Supreme Court allowed the appeal, set aside the judgment of the Calcutta High Court Single Judge, and upheld Criterion No. 5 as not arbitrary or unconstitutional. The Court dismissed Soutrik's challenge.
Law Points
- Article 136 of the Constitution of India
- Article 14 of the Constitution of India
- Judicial review of administrative policies
- Exhaustion of appellate remedies
- Principle of estoppel
- Public interest in educational admissions
