Isabella Mariam

The High Court of Chhattisgarh Single Bench of Justice Arvind Kumar Verma has dismissed a writ petition challenging the scheduling of final examinations by two different universities which resulted in overlapping exam dates. The court held that it could not exercise writ jurisdiction to modify examination timetables prepared by independent academic institutions. Consequently, the petition seeking rescheduling of examinations from two separate universities was dismissed in its entirety.

The petitioner, a 34-year-old student residing in Bilaspur, Chhattisgarh, filed the writ petition in person before the High Court under Article 226 of the Constitution of India. He sought judicial intervention for a clash in final examination dates between two academic programs he was pursuing concurrently: a Master of Social Work (M.S.W.) from Pt. Sundarlal Sharma (Open) University and a Bachelor of Law (LL.B.) Part-III (2nd Semester) from Atal Bihari Vajpayee Vishwavidyalaya.

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The petition named as respondents the State of Chhattisgarh through its Higher Education Department, Registrars and Examination Controllers of both the aforementioned universities. The petitioner contended that his readmission to the M.S.W. program was pursuant to a notification issued by Pt. Sundarlal Sharma (Open) University and argued that the examination schedules of both universities were directly conflicting, with at least four subjects scheduled on the same date and time.

He further submitted that such scheduling undermined the intent of the University Grants Commission (UGC), which had issued a revised notification permitting the simultaneous pursuit of two degrees. The petitioner referred to the Government of Chhattisgarh’s steps towards implementing the National Education Policy (NEP) 2020, including the constitution of a Task Force and directions to all State universities to make curricula more inclusive.

In his plea, the petitioner claimed that the conflicting schedules violated Article 21 of the Constitution of India, which guarantees the right to life and personal liberty. He alleged that there was mismanagement and lack of institutional commitment towards facilitating dual-degree programs, and he sought a judicial stay on the examination schedules announced by both institutions until the final adjudication of the matter.

The petition specifically requested the court to direct the respondent authorities to modify the examination timetable so that both sets of examinations would be conducted at separate times or on different dates, thereby allowing the petitioner to appear in all papers.

Representing the State, Government Advocate Mr. Satish Gupta appeared on behalf of Respondent No.1. Mr. Prateek Singh Thakur, appearing for Mr. Anoop Majumdar, represented Respondents No.2 and 4. Ms. Hamida Siddiqui represented Respondents No.3 and 5.

Justice Arvind Kumar Verma recorded in the order: "Taking into consideration the fact that the relief which has been sought by the petitioner cannot be granted in exercise of writ jurisdiction and the petitioner has no locus to direct the respondent authorities to make modifications in the final examination timetable for the two academic programmes, i.e. M.S.W. from Pt. Sundarlal Sharma (Open) University and LL.B (Part-III, 2ND Semester) from Atal Bihari Vajpayee Vishwavidyalaya, in view of the considered opinion of this Court, no case is made out for any interference."

The Court acknowledged that the petitioner sought equitable academic opportunities through adjustments in examination schedules. However, it found that the judicial forum was not the proper channel for seeking such relief. The petitioner's plea rested on the contention that academic institutions must account for dual-degree candidates when framing examination timetables. Nonetheless, the Court held that such decisions fell under the exclusive domain of academic and administrative discretion of universities.

Additionally, the Court noted that while the petitioner had relied on UGC guidelines and state policy directions under NEP 2020, no statutory right or enforceable obligation upon the universities to alter their schedules had been established.

"The petitioner has not brought on record any binding legal mandate or provision under which such scheduling changes could be compelled by judicial intervention."

The Court further observed: "Prima facie, there appears to be mismanagement and lack of commitment in the implementation of the policy allowing the pursuit of two degrees simultaneously..."

However, the Court did not find sufficient grounds to interfere, holding that administrative arrangements for examination schedules must be managed by the concerned institutions without judicial intrusion unless clear illegality or arbitrariness is established.

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The High Court issued the following conclusive direction: "Accordingly, the petition being devoid of any merit is liable to be and is hereby dismissed."

No interim relief was granted and the examination schedules issued by both Pt. Sundarlal Sharma (Open) University and Atal Bihari Vajpayee Vishwavidyalaya were upheld.

Advocates Representing the Parties:

For the Petitioner: Mr. Satyendra Prakash Suryawanshi (Petitioner-in-person)

For the Respondents: Mr. Satish Gupta, Government Advocate, Mr. Prateek Singh Thakur, Advocate, Hamida Siddiqui, Advocate

Case Title: Satyendra Prakash Suryawanshi v. State of Chhattisgarh & Ors.

Neutral Citation: 2025: CGHC:26112

Case Number: WPC No. 3068 of 2025

Bench: Justice Arvind Kumar Verma