Case Note & Summary
The Supreme Court allowed an appeal by Pratima Das, a law graduate from Manav Bharti University, seeking release of her academic documents. The Appellant had completed her BA.LLB programme but faced delays due to an investigation into the University for fake degrees, which led to seizure of records. Her name was in the green register but not in the admission disclosure list, with another student's name incorrectly listed. The High Court had disposed of a related Public Interest Litigation, citing disputed facts and directing students to approach competent courts. The Supreme Court found that the University admitted mistakes and the Appellant had passed all exams, causing her career prejudice. The Court directed the University to release the documents within four weeks, holding that students should not suffer due to institutional errors.
Headnote
The Supreme Court allowed the appeal filed by Pratima Das seeking release of her marksheets and degree from Manav Bharti University -- The Appellant had completed her BA.LLB programme but could not procure documents due to a First Information Report investigation against the University for fake degrees -- The High Court had disposed of a Public Interest Litigation by relegating students to competent courts, citing disputed facts -- The Supreme Court held that the Appellant's name was reflected in the green register and she had passed all examinations, with the University admitting mistakes in the admission disclosure list -- The Court directed the University to release the documents within four weeks, noting the grave prejudice to the Appellant's career -- The judgment emphasizes institutional accountability and relief for students not at fault
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Issue of Consideration: The Issue of whether the Appellant is entitled to release of her academic documents despite discrepancies in university records, and the appropriate remedy for students affected by institutional failures
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Final Decision
The Supreme Court allowed the appeal, directing Manav Bharti University to release the Appellant's marksheets for 5th to 10th semester and degree within four weeks, and imposed costs of Rs. 50,000 on the University payable to the Appellant
2026 LawText (SC) (01) 21
Civil Appeal No. of 2026 (Arising out of SLP(Civil) No. 15180 of 2025)
VIKRAM NATH J. , AUGUSTINE GEORGE MASIH J.
State of Himachal Pradesh, Manav Bharti University, Others
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Nature of Litigation: Civil appeal seeking release of academic documents (marksheets and degree) due to university record discrepancies
Remedy Sought
Appellant seeking release of her marksheets for 5th to 10th semester and degree in law from Manav Bharti University
Filing Reason
Inability to procure academic documents due to investigation against University for fake degrees and discrepancies in records
Previous Decisions
High Court disposed of Public Interest Litigation (CWPIL No.22 of 2022) by relegating students to competent courts; Appellant's earlier writ petitions (CWP No.1480/2024 and CWP No.6075 of 2024) were disposed of or withdrawn
Issues
Whether the Appellant is entitled to release of her academic documents despite discrepancies in university records
Whether the High Court erred in disposing of the Public Interest Litigation by directing students to approach competent courts
Submissions/Arguments
Appellant's counsel argued that she passed all exams, her name was in the green register, and University mistakes should not prejudice her career
Respondents submitted that documents could not be verified due to incomplete records and the Verification Committee could not alter documents
Ratio Decidendi
Students should not suffer career prejudice due to institutional lapses and record discrepancies; educational institutions have a duty to maintain accurate records and provide documents to bona fide students
Judgment Excerpts
The Appellant has preferred this appeal seeking release of her marksheets of the 5th to 10th semester and degree in law
The PIL, ultimately came to be disposed of by the Court by observing that it was not in a position to determine such disputed questions of facts
The affidavits filed by MB University made it amply clear that the University acknowledged the factum of mistake having occurred at their end
Procedural History
Appellant admitted to Manav Bharti University in 2017; Investigation in 2019 led to seizure of records; Students filed Public Interest Litigation (CWPIL No.22 of 2022) in High Court; High Court disposed of PIL on 20.12.2024; Appellant filed Special Leave Petition leading to Supreme Court appeal
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