Introduction:

The case of CH. Muralidhar v. State of Telangana & Others (Writ Petition No. 6865 of 2026) came before the Telangana High Court raising a significant issue concerning the rights of students vis-à-vis private educational institutions. The matter revolved around whether a college could retain a student’s original academic certificates as leverage to recover alleged dues after the student had discontinued his course.

The petitioner, CH. Muralidhar, had enrolled in the first year of a Bachelor of Technology (B.Tech.) program in Mechanical Engineering at Siddhartha Institute of Technology and Sciences. At the time of admission, as is common practice, the college had taken custody of his original academic certificates, including his Secondary School Certificate (SSC) memo, Intermediate marks memo, Transfer Certificate, Study and Conduct Certificates, and other essential documents.

However, the petitioner attended classes for only about fifteen days before an unfortunate incident altered the course of events. A quarrel reportedly took place between the petitioner and certain senior students, during which he alleged that he was physically assaulted. The situation escalated further when one of the senior students involved in the incident allegedly committed suicide, following which a criminal case was registered against the petitioner.

In light of these developments, the petitioner discontinued his studies and returned to reside with his family in Khammam district. Subsequently, he sought the return of his original certificates, which were crucial for securing employment and rebuilding his life. Despite making repeated attempts, including a written application dated 04.02.2026 sent via registered post, the college failed to return the documents and instead demanded payment of the entire fee for the remaining three years of the course.

Aggrieved by this refusal, the petitioner approached the High Court under Article 226 of the Constitution, seeking a direction to the college to return his original certificates. The matter was heard by Justice Juvvadi Sridevi, who examined the legality of the college’s actions in light of established legal principles.

Arguments by the Petitioner:

The petitioner advanced compelling arguments asserting that the actions of the college were illegal, arbitrary, and violative of his fundamental rights.

Firstly, it was contended that the original certificates submitted at the time of admission were the personal property of the petitioner. These documents represented his academic credentials and were indispensable for pursuing employment or further education. Their retention by the college, therefore, amounted to an unlawful deprivation of his property and a violation of his right to livelihood.

Secondly, the petitioner argued that he had discontinued his studies due to extraordinary and compelling circumstances, including the alleged physical assault by senior students and the subsequent criminal case. It was emphasized that his discontinuation was not voluntary in the ordinary sense but was necessitated by circumstances beyond his control.

Thirdly, it was submitted that the college had acted in a coercive and high-handed manner by refusing to even accept his application for return of certificates and by imposing an unreasonable condition that he must pay the entire course fee for the remaining three years. Such a demand, according to the petitioner, had no legal basis.

Fourthly, the petitioner asserted that there were no outstanding dues payable by him, and even if there were, the college could not enforce such claims by withholding his original certificates. The petitioner emphasized that there are established legal mechanisms available for recovery of dues, and the college’s actions were in violation of those principles.

Fifthly, the petitioner highlighted that he had made bona fide efforts to retrieve his documents, including sending a formal application through registered post, which was duly received by the college. The continued inaction on the part of the college demonstrated arbitrariness and disregard for legal norms.

Finally, it was argued that the retention of certificates had caused severe prejudice to the petitioner, as it prevented him from seeking employment and rebuilding his life after the traumatic events he had experienced.

Arguments by the Respondent (College and Authorities):

Although the judgment primarily reflects the Court’s reasoning, the stance of the respondent college can be reasonably inferred from the circumstances and submissions on record.

The college appeared to justify its retention of the certificates on the ground that the petitioner had discontinued the course midway and was therefore liable to pay the fee for the remaining duration of the program. It likely contended that the fee structure and institutional policies permitted such recovery to compensate for the loss incurred due to the vacant seat.

The institution may have also argued that the petitioner had voluntarily taken admission and was aware of the terms and conditions governing the course, including the financial obligations. Therefore, discontinuation of the course did not absolve him of liability to pay the agreed fees.

Additionally, the college might have sought to justify its actions as a common administrative practice aimed at ensuring compliance with financial commitments by students.

However, it is evident from the Court’s observations that the college did not dispute the fact that the certificates belonged to the petitioner or that they had been retained after he discontinued his studies.

Court’s Observations and Judgment:

Justice Juvvadi Sridevi delivered a clear and unequivocal judgment, emphasizing the rights of students and the limits of institutional authority.

1. Ownership of Certificates

The Court categorically held that the original academic certificates are the personal property of the student. These documents are not merely administrative records but represent the individual’s academic achievements and identity.

The Court observed that there was no dispute regarding the fact that the petitioner had submitted his original certificates at the time of admission and that he had subsequently discontinued the course. In such circumstances, the continued retention of these documents by the college was unjustified.

2. Lack of Authority to Retain Documents

The Court made it unequivocally clear that the college had no authority whatsoever to retain the petitioner’s original certificates. It held that such retention was arbitrary, illegal, and unsustainable in law.

The judgment emphasized that educational institutions do not acquire any proprietary rights over students’ documents merely because they are submitted at the time of admission.

3. Recovery of Dues Cannot Be Coercive

A key aspect of the judgment was the Court’s observation that even if the college had a legitimate monetary claim against the petitioner, it could not enforce such a claim by withholding his certificates.

The Court stated that the proper remedy available to the college was to initiate appropriate legal proceedings for recovery of dues. Coercive methods, such as retention of certificates, were impermissible.

4. Protection of Student Rights

The Court recognized the broader implications of the issue, noting that withholding certificates could severely impact a student’s ability to secure employment or pursue further education. Such actions, therefore, have serious consequences for the individual’s future and livelihood.

5. Direction to Return Certificates

In light of the above findings, the Court allowed the writ petition and directed the respondent college to forthwith return all the original certificates and documents belonging to the petitioner.

The use of the term “forthwith” underscores the urgency and importance attached by the Court to the petitioner’s grievance.