Simplified Explanation of the Judgment

This case involved a student of R.K.K. College, Purnea (affiliated to Bhupendra Narayan Mandal University, Madhepura), who sought a direction from the Patna High Court for the declaration of his Bachelor of Science (Chemistry Hons.) final result and issuance of his mark sheet and degree.

The petitioner had a long and inconsistent academic record. He passed Part-I of the B.Sc. (Hons.) course in 2014. In Part-II (2015), he failed in Chemistry (Hons.) and Mathematics (subsidiary). In 2016, he again attempted Part-II, cleared Mathematics but failed Chemistry (Hons.). In 2017, he did not appear at all. Despite failing, he was promoted to Part-III under the University’s examination regulations, which allow promotion with “carry over” of certain failed papers.

However, he never attempted Part-III exams in 2016, 2017, or 2018. He finally appeared in 2019. The University, citing Regulation 7.1, withheld his result, stating that no student can be admitted to Part-III unless he has cleared Part-II. The petitioner admitted he had not cleared Part-II, but argued that since the University permitted him to sit in Part-III, it could not later withhold his result.

He relied on the Supreme Court decision in Shri Krishan v. Kurukshetra University (1976) 1 SCC 311, which held that once a student is allowed to take an exam, the University cannot later cancel or withhold the result.

The University countered that the petitioner had repeatedly failed in Chemistry (Hons.) and exhausted the maximum permissible attempts under Regulation 7.1. The rule allows a student to carry forward failed subjects only for three consecutive examinations. Since the petitioner missed several years and never cleared Chemistry Part-II, he was ineligible for Part-III.

The High Court examined earlier precedents, including:

• Mihir Kumar Jha v. Bhupendra Narayan Mandal University (CWJC No. 21660/2013), where similar arguments were rejected, holding that Shri Krishan cannot be universally applied and that academic standards must be preserved.
• Sima Bharti v. State of Bihar (CWJC No. 4605/2018), where promotion to Part-III contrary to regulations was struck down.
• Ruchi Rachna v. State of Bihar (CWJC No. 6114/2018), where the Court refused relief to a student appearing in contravention of rules.

The Court held that allowing publication of the petitioner’s result would perpetuate illegality, destroy academic standards, and violate Article 14 of the Constitution since other similarly placed students may have been denied such opportunities.

It further directed the Vice-Chancellor to conduct an inquiry into how the petitioner was permitted to sit for Part-III contrary to regulations.

Accordingly, the writ petition was dismissed.

Significance or Implication of the Judgment

• For students: This case highlights that appearing in an exam without fulfilling eligibility criteria does not create a right to demand results. Reliance on technicalities or University errors will not help if the student has not met academic requirements.
• For universities: Institutions must enforce regulations strictly and ensure no ineligible student is allowed to sit in higher exams. If such lapses occur, inquiries and accountability are necessary.
• For academic integrity: The judgment upholds academic standards, ensuring that promotions and degrees are not obtained by bypassing eligibility conditions.

Legal Issue(s) and Court’s Reasoning

• Whether a student who fails Part-II can demand declaration of Part-III result if allowed to sit in exam?
  • No. The Court held that mere appearance does not override eligibility rules; results cannot be declared in contravention of regulations.
• Whether the precedent of Shri Krishan v. Kurukshetra University applied?
  • No. That principle is not of universal application. The facts here showed repeated failures and expiry of permissible attempts.
• Whether denying relief violates Article 14?
  • No. Granting relief would instead violate Article 14 by unfairly favoring one student over others who complied with regulations.

Judgments Referred by Parties

• Shri Krishan v. Kurukshetra University, (1976) 1 SCC 311

Judgments Relied Upon by Court

• Mihir Kumar Jha v. Bhupendra Narayan Mandal University, CWJC No. 21660 of 2013 (Patna HC, 2014)
• Sima Bharti v. State of Bihar, CWJC No. 4605 of 2018 (Patna HC, 2018)
• Ruchi Rachna v. State of Bihar, CWJC No. 6114 of 2018 (Patna HC, 2018)

Case Title

Md. Helal v. State of Bihar & Ors.

Case Number

Civil Writ Jurisdiction Case No. 7882 of 2020

Citation(s)

2021(1)PLJR 528

Coram and Names of Judges

Hon’ble Mr. Justice Chakradhari Sharan Singh (Oral Judgment dated 04.01.2021)

Names of Advocates and who they appeared for

• For the Petitioner: Mr. Jitendra Kumar Pandey
• For the State: Mrs. Shilpa Singh, G.A.-12; Ms. Abhanjali, AC to G.A.-12
• For the University: Mr. Ritesh Kumar

Link to Judgment

https://patnahighcourt.gov.in/viewjudgment/MTUjNzg4MiMyMDIwIzEjTg==-3lT–ak1–JN9kU1w=

If you found this explanation helpful and wish to stay informed about how legal developments may affect your rights in Bihar, you may consider following Samvida Law Associates for more updates.