Introduction:

In the case of Harshi Ramjiyani vs. State of Maharashtra & Ors. (Writ Petition No. 10643 of 2023), the Bombay High Court upheld Mumbai University’s decision to cancel the admission of Harshi Ramjiyani after four semesters due to insufficient marks in the International Baccalaureate (IB) programme. The division bench of Justices A.S. Chandurkar and M.M. Sathaye ruled that the Court cannot direct the university to lower the cut-off standard if a student fails to secure the required grades. The petitioner had enrolled in the B.Voc (Interior Design) degree course based on a provisional eligibility certificate issued by Mumbai University, which required a minimum of 24 IB credit points. Despite completing two years of the course, the petitioner’s admission was revoked when it was revealed that she had not achieved the necessary IB score. The petitioner argued that cancelling her admission after completing four semesters was unfair and relied on precedent where the Court had protected students from such cancellations. However, the university maintained that it had acted per its policies, as the student had failed to meet the required academic standards. The Court, siding with the university, observed that institutions are entitled to set academic benchmarks, and leniency in such cases would compromise academic integrity. Consequently, the petition was dismissed.

Arguments of Both Sides and Court’s Judgment:

The petitioner, Harshi Ramjiyani, had applied for admission to Mumbai University’s B.Voc (Interior Design) degree course after completing her 10th-grade education and enrolling in the International Baccalaureate (IB) Diploma Programme. She was granted a prima facie eligibility certificate based on predicted grades, conditional upon securing at least 24 credit points in the IB diploma. The petitioner began her studies and completed four semesters, progressing under the Allowed to Keep Terms (ATKT) system despite not passing all subjects. However, in 2022, she received an email from the university notifying her that her admission had been revoked because she had failed to meet the 24-credit requirement.

The petitioner challenged the university’s decision, contending that it was unjust to cancel her admission after completing two years of study. She relied on Rohan Ravindra Thatte v. University of Mumbai & Ors. (2024 LiveLaw (Bom) 29), where the Bombay High Court had quashed the university’s decision to declare a student ineligible for the LL.B. course after he had completed two-thirds of the programme. The petitioner argued that students should not be penalized for administrative lapses or delays in determining eligibility.

Mumbai University, represented by the respondents, countered that the petitioner had failed to meet the requisite IB credit points and had only submitted her IB certificate in August 2022, long after her admission. The university maintained that it had made reasonable accommodations by issuing provisional eligibility certificates based on predicted grades, but students had to ultimately meet the set academic criteria. The university contended that it had the right to enforce eligibility requirements to maintain academic standards and that the petitioner’s situation was different from the Thatte case, as that case did not involve provisional eligibility based on predicted grades.

The High Court ruled in favour of Mumbai University, affirming its decision to revoke the petitioner’s admission. The Court noted that the university had not erred in setting a minimum eligibility requirement of 24 IB points, stating that it was not within the Court’s jurisdiction to lower academic standards. The bench emphasized that students choosing to pursue IB diplomas must account for delays in results and the risks associated with predicted grades. It held that universities and colleges could not be held responsible when students failed to meet eligibility criteria despite receiving provisional admission. The Court also referred to Parakh Jaiprakash Shahal v. Thakur College of Science and Commerce & Ors. (2017), where it was held that an IB student who failed to achieve the required marks could not claim wrongful cancellation of admission.

Based on these findings, the Court dismissed the petition, concluding that Mumbai University had acted within its authority in rescinding the petitioner’s admission.