Isabella Mariam

The High Court of Delhi Division Bench of Justice Prathiba M. Singh and Justice Rajneesh Kumar Gupta held that candidates who fail to comply with gate entry deadlines for national examinations cannot seek special accommodations or re-scheduling on sympathetic grounds. The Court dismissed an appeal seeking directions for a re-test or allocation of an alternative slot for a candidate who arrived at the examination centre six minutes after the gate had closed for the Common University Entrance Test (CUET) UG 2025. Citing the importance of maintaining discipline and the logistical complexities of conducting a standardized examination for over 13.54 lakh students, the Court refused to entertain claims of disparate implementation or procedural unfairness. The Court concluded that the instructions in the admit card and information bulletin were unambiguous and binding, and enforcement of these timelines by the National Testing Agency (NTA) was appropriate and constitutionally valid.

The appellant, an 18-year-old student who completed her CBSE Class 12th examination from Guru Harkrishan Public School, Delhi, had applied to appear in the CUET UG 2025, conducted by the National Testing Agency (NTA). The online application for the CUET examination opened on 1st March 2025. The examination is a computer-based test used for admissions in various Central, State, Private, and Deemed Universities across India. The appellant selected five subjects: English (Language), Economics/Business Economics (Domain), Geography/Geology (Domain), Political Science (Domain), and the General Aptitude Test.

Also Read: SC Upholds Cancellation Of Land Allotment To Trust | Terms Defaults A Deliberate Strategy To Evade Payment | Raps UPSIDC For Non-Transparent Allocation Violating Public Trust Doctrine

The appellant was issued an admit card for examinations scheduled from 13th May to 16th May 2025. Her first scheduled examination covered three subjects—English, Political Science, and General Aptitude—on 13th May 2025, from 09:00 A.M. to 12:00 Noon. The admit card explicitly instructed candidates to report by 07:00 A.M. and noted that the gate would close at 08:30 A.M. sharp. These instructions were reiterated in the information bulletin.

The appellant reached the designated examination centre, RK Digital Computer Centre 2, Shakti Nagar, Delhi, at 08:36 A.M., six minutes past the gate closing time. She was denied entry by the invigilators and subsequently missed the examination.

Following this, the appellant filed W.P.(C) 6854/2025 before the Single Judge of the High Court, seeking a writ of mandamus for reallocation to another slot or re-test. Additionally, the petition sought a declaration that Clauses 7.5 and 8.9 of the information bulletins were ultra vires the Constitution.

In response, the NTA filed a counter affidavit asserting that allowing candidates who missed their slot would compromise the fairness and standardization of the examination. They stated that shifts were determined based on options exercised, technical, and administrative considerations. Clause 7.5 of the bulletin specified that no change in date or shift would be entertained.

The Single Judge dismissed the petition on 28th May 2025, holding that the admit card and information bulletin jointly governed candidate obligations, including entry timings. The Single Judge concluded that the petitioner had violated unambiguous instructions and could not claim relief on that basis.

Challenging this decision, the appellant filed LPA 392/2025. Counsel for the appellant raised three primary arguments:

1. Clause 8.2 of the information bulletin only stated that late candidates may miss instructions, not that entry would be barred.

2. Implementation of gate closing timings was inconsistent across centres.

3. Missing the exam would preclude the appellant from admission to multiple universities, severely affecting her educational prospects.

The appellant argued for a lenient approach due to the minor delay and urged the Court to direct NTA to provide a re-test or allow appearance in a remaining slot before 3rd June 2025.

The respondent NTA, represented by standing counsel, argued that instructions in the admit card were binding and harmoniously read with the information bulletin. Clause 8.2 pertained to the examination hall entry, while the gate closing time related to the outer boundary of the centre. Further, the NTA stated that granting special treatment to one candidate could lead to logistical complications and unfair advantage, undermining the integrity of a standardized, large-scale exam process.

The Division Bench observed, "The Court is also extremely conscious of the fact that the non-appearance of a candidate in the entrance examinations, such as the CUET examination, can have a negative impact on the student’s career." However, the Court maintained that maintaining examination discipline and sanctity was paramount.

The Court recorded, "Clause 8.1 of the information bulletin dated 1st March, 2025, stipulates that candidates have to report at the Examination Centre well in time i.e., 02 hours before the commencement of the examination." The Court explained that a buffer of two hours ensured students had ample time to address delays and settle before the test.

In regard to Clause 8.2, the Court stated, "When read with the instructions stipulated in the admit card, it is clear that there is no conflict whatsoever." The Bench clarified that the instruction requiring students to take their seats immediately after opening of the hall does not override the gate closure rule mentioned explicitly in the admit card.

Responding to the appellant’s reliance on Clause 8.2, the Court noted, "Clause 8.2... cautions candidates that there could be traffic jams, train/bus delays etc., which may prevent them from reaching in time. Candidates are asked to take their seats when the Examination hall opens at 7am." The Court reasoned that this does not negate the 08:30 A.M. gate closing deadline.

Addressing the plea for equitable treatment based on inconsistent enforcement at other centres, the Bench observed, "Such discrimination cannot be considered as a valid ground to interfere, inasmuch as, all students who violate the gate closing time, would be acting contrary to the instructions." It stated that "Article 14 of the Constitution cannot be applied to compare persons violating the rules of the examination."

Regarding re-scheduling requests, the Court referred to NTA’s affidavit and noted, "Permitting selective rescheduling... would lead to an unequal distribution of candidates across different shifts, thereby affecting the normalization procedure."

On the broader impact, the Court held, "The CUET UG examination is an exam where more than 13.54 lacs students from across the country appear. If exceptions are made... the timely conduct of the exam, the timely announcement of results and timely admission to colleges and Universities is all likely to be jeopardised."

Sympathetically addressing the appellant’s situation, the Court acknowledged that she had also applied for other examinations like that of Guru Gobind Singh Indraprastha University.

The Court concluded that, "Clause 8.2 of the information bulletin does not appear to be in conflict with the instructions in the admit card and the argument to that effect would not be tenable."

It recorded that, "One may actually feel that nothing would have happened had the student been given entry as she was only six minutes late. If the said decision to let her in was taken by the concerned Invigilator or Supervisor, on the spot, it would have been fine. However, the authorities cannot be blamed for enforcing the rule of gate closing timings strictly."

Also Read: Neither The Appellant Nor The Private Respondents Could Have Been Appointed But For Equitable Jurisdiction | J&K High Court Refuses Retrospective Appointment, Upholds Seniority Based On Merit

The Court stated, "The Court cannot lose sight of the discipline that is required to be maintained in the conduct of such examinations... The same would not be sufficient by itself to give directions to the NTA..."

Thus, the appeal was dismissed. The Court stated, "Under these circumstances, the present appeal is dismissed. Pending application(s), if any, also stand disposed of."

Advocates Representing the Parties:

For the Petitioner: Mr. Vinayak Goel and Mr. Alexander Mathai Paikaday, Advocates

For the Respondents: Mr. Sanjay Khanna, Standing Counsel with Ms. Pragya Bhushan, Mr. Tarandeep Singh and Ms. Vilakshana Dayma, Advocates for NTA

Case Title: Ms. Sadhana Yadav v. Union of India & Ors.

Neutral Citation: 2025: DHC:4823-DB

Case Number: LPA 392/2025

Bench: Justice Prathiba M. Singh, Justice Rajneesh Kumar Gupta

[Read/Download order]