Introduction:

In the case of M/S ND Info Systems Pvt. Ltd. v. Rehabilitation Council of India [O.M.P.(I) (COMM.) 382/2025; 2025 LiveLaw (Del) 1204], the Delhi High Court, presided over by Justice Jasmeet Singh, was called upon to adjudicate an urgent plea concerning admissions of nearly 48,000 specially abled candidates across India to diploma courses in the 2025–26 academic session. The dispute arose between the Rehabilitation Council of India (RCI), the statutory body overseeing such admissions, and M/S ND Info Systems Pvt. Ltd., the private entity entrusted through a tender process with the task of conducting the All India Online Aptitude Test and preparing the merit list. At the heart of the dispute lay a contractual disagreement: while the private organiser claimed the exclusive contractual right to compile and publish the merit list, the RCI unilaterally published its own list after delaying approval of the one submitted by the petitioner. Alleging that such unilateral action was arbitrary and mala fide, the petitioner approached the High Court, seeking to stall the admission and counselling process until the arbitral tribunal could adjudicate the dispute. The High Court, however, declined to stay the admissions, reasoning that the larger public interest—the academic future and employability of thousands of specially abled candidates—must prevail over the private contractual dispute.

Arguments of the Petitioner:

The petitioner, represented by Senior Advocate Jayant Mehta along with advocates Tanuj Khurana, Honey Jain, Ashish Batra, and Om Shelat, contended that it was the rightful entity authorised under the tender contract to compile, publish, and declare the final merit list for admissions following the All India Online Aptitude Test. It argued that the RCI had been in constant correspondence with the petitioner and had, in fact, urged it to take steps toward finalising the results. The petitioner highlighted that after it had duly prepared the merit list in compliance with the contractual provisions, the RCI deliberately delayed granting approval and thereafter took an abrupt and unilateral decision to discard the petitioner’s list and publish its own. This, the petitioner contended, amounted to a breach of contract, violated the principles of fairness and transparency, and was an attempt by the RCI to unlawfully curtail its exclusive contractual rights. The petitioner submitted that such arbitrary action directly affected the lives of 48,000 specially abled candidates who had registered for the examination and whose admissions were now left uncertain. It further argued that unless the Court intervened and stalled the counselling and admissions process, irreparable harm would be caused not only to its contractual rights but also to the careers of the candidates. It requested that the Court prevent the admissions from proceeding until the arbitral tribunal adjudicated the contractual dispute, thereby preserving the sanctity of the agreement.

Arguments of the Respondent:

The Rehabilitation Council of India, represented by Advocate Manish Kumar, defended its conduct and asserted that as the statutory authority responsible for regulating the courses, it retained the ultimate control over the admissions process. The RCI sought to justify its decision to publish the merit list by pointing to its regulatory responsibilities and the larger public interest in ensuring that admissions were not delayed. While the RCI did not provide a satisfactory explanation for its delay in approving the petitioner’s list or for why it rejected it, it maintained that as a statutory body it had the authority to oversee and, if necessary, intervene in the process to safeguard standards. The respondent attempted to argue that the petitioner’s grievance was essentially contractual in nature and, therefore, should be resolved in arbitration rather than by stalling the admissions process. It also emphasized that the welfare of students could not be held hostage to a contractual disagreement between the Council and its appointed agency.

Court’s Observations and Judgment:

Justice Jasmeet Singh, after hearing both parties, delivered a judgment that placed paramount emphasis on the welfare of specially abled candidates. The Court noted that staying the admission process would have disastrous consequences for nearly 48,000 specially abled students who had been waiting for admission opportunities after a gap of two years. The bench observed that any disruption in the admission process would not only delay the commencement of classes but would also cause immense distress, uncertainty, and the possible loss of an academic year—consequences that could not be compensated monetarily. The Court remarked: “To my mind, in such matters, the welfare of candidates must be kept safe and at the forefront, as the primary objective of the learning system is to ensure that learning opportunities are not disrupted or denied on account of contractual disputes between parties as in the present case is. The academic sessions, career progression, and long-term rehabilitation of thousands of specially abled candidates are at stake. Any disruption in the admission process has a cascading effect as it not only delays commencement of classes, but it also causes distress, uncertainty, and loss of academic year, which cannot be compensated in monetary terms.”

The Court took an adverse view of the RCI’s conduct, noting that its unilateral decision to publish its own list after corresponding with the petitioner raised serious questions of arbitrariness and lack of fairness. Justice Singh observed that the RCI had failed to satisfactorily explain why it did not accept the petitioner’s list or why approval was delayed. Describing the action as prima facie arbitrary and mala fide, the Court noted that it “cries foul of fairness.” Nonetheless, despite finding fault with the RCI, the Court refused to halt the admissions, stating that the larger public interest outweighed the contractual grievances of the petitioner. The Court emphasised: “Nearly 48,000 specially abled candidates have registered for admission after a gap of two years. Their academic careers and future employability hinge upon timely commencement of the 2025–26 session. I cannot permit a stalemate situation between the petitioner and respondent to indefinitely stall the counselling and admission process. The larger public interest in ensuring continuity of education far outweighs the contractual disagreements between the parties… The balance of convenience, therefore, tilts heavily in favour of allowing the admission process to proceed in the interest of candidates, even if it means that the petitioner’s contractual grievances are left to be resolved in arbitration.”

Thus, while directing that the petitioner’s contractual grievances could be pursued before the arbitral tribunal, the Court categorically refused to stall the counselling and admissions. This decision reinforced the judicial approach of prioritising the rights of students and candidates in educational matters over private contractual disputes, particularly when the candidates involved belong to a marginalised section of society such as the specially abled.

Broader Significance:

The judgment is significant not only for its resolution of the immediate dispute but also for the principles it underscores. By giving precedence to the welfare of specially abled candidates, the Court reaffirmed the constitutional vision of inclusivity and equal opportunity. It sent a clear message that educational opportunities for marginalised groups cannot be disrupted by contractual stalemates. At the same time, the Court’s censure of the RCI’s arbitrary conduct highlighted the importance of fairness, transparency, and accountability in regulatory bodies. The case also underscores the judiciary’s role in balancing competing interests—private contractual rights versus public interest in education—and choosing the course that best serves the larger societal good. In doing so, the judgment contributes to jurisprudence on the interplay between contractual law, statutory authority, and the fundamental right to education and livelihood, particularly for vulnerable groups.