Introduction:
In a compassionate and precedent-sensitive judgment, the Rajasthan High Court, in Narendra Mahal v. State of Rajasthan & Ors. [2025 LiveLaw (Raj) 346], delivered by Justice Sameer Jain, came to the rescue of a NEET-qualified medical aspirant whose candidature had been rejected and whose Rs. 5 lakh security deposit was forfeited merely because he deposited his college fee a day late. The petitioner, a fatherless student from a humble background, had missed the deadline due to the unfortunate demise of his great grandmother, coupled with preceding public holidays. The Court observed that in such situations, procedural rigidity must yield to substantive justice and human empathy. Justice Jain’s judgment stands as a compelling reaffirmation that the justice system must protect young aspirants who work tirelessly to fulfill their dreams of higher education. The Court sharply criticized the conduct of the Rajasthan NEET Counselling Board for forfeiting the deposit, calling it a case of “unjust enrichment” and directing that the petitioner be allowed to participate in the next round of counselling with his deposit adjusted toward the college fee.
Arguments of the Petitioner:
The petitioner, a meritorious NEET candidate, had cleared the examination and deposited Rs. 5 lakh as a security deposit during the counselling process. He was subsequently allotted a seat in a private medical college in the second round and required to deposit an additional Rs. 18.90 lakh as admission fee within a short period. Counsel for the petitioner argued that due to his great grandmother’s sudden death just a day before the deadline, coupled with two prior public holidays, he was unable to make the payment within the prescribed time. However, despite this genuine reason, the Counselling Board refused to accept the fee, canceled his seat, and forfeited his Rs. 5 lakh deposit.
The petitioner’s counsel contended that this approach was excessively harsh, arbitrary, and violative of the principles of natural justice. It was argued that such a rigid insistence on deadlines, especially when the delay was neither deliberate nor significant, defeated the very spirit of fairness that must guide administrative and educational processes. The counsel stressed that the petitioner’s circumstances were beyond his control and that he had made earnest efforts to comply with the requirements immediately after the holidays and the bereavement.
The petitioner also contended that the forfeiture of the security deposit amounted to “unjust enrichment” by the respondents since there was no demonstrable loss suffered by the Board. The amount, once forfeited, did not go toward any public purpose but instead was absorbed into institutional coffers without legal or ethical justification. The petitioner argued that such forfeiture violated the principles laid down by the Supreme Court in Mafatlal Industries Ltd. & Ors. v. Union of India & Ors., where the doctrine of unjust enrichment was clearly enunciated to prevent state or institutional authorities from retaining money not legally due to them.
The petitioner’s counsel further emphasized that the impugned action was contrary to Article 14 of the Constitution, which guarantees equality before law and prohibits arbitrary administrative action. The doctrine of proportionality, they argued, must apply — meaning that even if there was a technical lapse, the penalty imposed must not be so severe as to extinguish a student’s educational prospects. The petitioner’s case, they urged, represented the plight of thousands of economically disadvantaged students for whom every rupee represents the hard-earned contribution of family and well-wishers. Denying him the opportunity to continue his medical journey would result in irreversible injustice.
Arguments of the Respondents:
The respondents, representing the NEET Counselling Board and State authorities, defended their decision by arguing that the entire counselling process was governed by strict timelines and uniformly applicable rules as prescribed in the official information booklet. They asserted that the deadlines were integral to maintaining order, fairness, and administrative efficiency in the medical admission process, which involves thousands of candidates across the state.
According to the respondents, allowing exceptions or condoning delays on individual grounds could open the floodgates for litigation and create administrative chaos. They contended that all candidates were informed well in advance of the deadlines and that adherence to these was mandatory. The Board’s counsel argued that the petitioner’s delay, even if unintentional, could not be excused because doing so would compromise the integrity of the counselling process and set an undesirable precedent.
Further, the respondents sought to justify the forfeiture of the security deposit by asserting that the clause allowing such forfeiture was clearly mentioned in the information booklet to which all candidates had agreed. They maintained that the forfeiture was not punitive but procedural, serving as a deterrent against non-compliance and ensuring that seats were not wasted due to candidates failing to pay fees on time. They thus claimed that their actions were lawful, rule-bound, and in conformity with the established procedure applicable to all candidates.
Court’s Analysis and Judgment:
Justice Sameer Jain’s judgment began by acknowledging the sensitivity of the case, which involved the aspirations of a meritorious yet economically challenged student. The Court observed that while adherence to procedure is essential for fairness, the judicial system cannot allow procedural formalities to override the fundamental tenets of justice, equity, and compassion.
The Court examined the chronology of events, noting that the petitioner’s delay was caused by an exceptional circumstance — the death of his great grandmother — and exacerbated by two consecutive public holidays, leaving him without a practical opportunity to make the payment. The Court found the petitioner’s conduct bona fide and devoid of any mala fide intent.
Justice Jain remarked that while the respondents were right in emphasizing the need for uniformity, such uniformity cannot come at the cost of justice. The Court opined that administrative efficiency must serve, not subvert, the purpose of fairness. “Merely due to procedural irregularities or delays which could be condoned, the dreams of the petitioner need not be halted,” the bench stated.
The Court held that the forfeiture of the security deposit was an arbitrary act amounting to unjust enrichment, as the Board failed to demonstrate any loss or detriment caused by the petitioner’s brief delay. Referring to Mafatlal Industries Ltd. & Ors. v. Union of India & Ors., the Court underscored that unjust enrichment arises when an entity retains money that it is not legally entitled to keep. Since the Counselling Board could not clarify how the forfeited funds were accounted for or utilized, the Court concluded that the forfeiture lacked legal foundation.
Justice Jain powerfully articulated that “in the tussle between merits and money, the future of bona fide aspirants need not suffer.” The Court observed that medical aspirants are often compelled to deposit substantial sums within extremely short timelines, a practice that imposes undue hardship, especially on those from modest financial backgrounds. The Court criticized this as an exploitative system that prioritizes financial strictness over human considerations.
The judgment further expressed disapproval of the State’s attitude, noting that despite being a welfare state, it often functions as a “compulsive litigant,” showing little empathy for citizens. The Court remarked that it was “shocked and surprised” that no government department — not the Finance Department, not the Controller and Auditor General, nor any supervisory agency — had scrutinized the issue of unaccounted security deposits. Such indifference, the Court held, reflects poorly on the administration’s commitment to fairness and transparency.
Ultimately, the Court allowed the petition, directing the Counselling Board to permit the petitioner’s participation in the third round of counselling and to adjust the forfeited Rs. 5 lakh security deposit toward his college fee. The Court clarified, however, that the decision was specific to this case and should not be treated as a precedent. To ensure systemic introspection, Justice Jain directed the Registrar to forward a copy of the judgment to the National Medical Commission, the Ministry of Health and Family Welfare, and the Chief Secretary of Rajasthan.
The judgment thus stood not merely as a relief to an individual petitioner but as a larger statement against bureaucratic rigidity and financial arbitrariness in educational administration. It reinforced the judiciary’s role as a guardian of fairness, reminding authorities that welfare cannot coexist with exploitation or procedural indifference.