Introduction:

In a recent judgment, the Himachal Pradesh High Court, presided over by Justice Ajay Mohan Goel, dismissed a writ petition filed by a group of students challenging the decision to hand over a building constructed under the Rashtriya Uchchatar Shiksha Abhiyan (RUSA) scheme from Sardar Patel University, Mandi, to Maharaja Lakshman Sen Memorial College, Sundernagar. The case titled Aman Chauhan & Others v. State of Himachal Pradesh & Others [CWP No.10972 of 2025] raised the issue of whether students can influence decisions related to the location and allocation of university infrastructure. The petitioners argued that the decision violated their legitimate expectations as they had enrolled in the University believing classes would be conducted from the said college building. On the other hand, the State contended that infrastructure decisions fall within the exclusive policy domain of statutory bodies and the government, and students cannot dictate such administrative matters. The Court upheld this stance, ruling that decisions concerning infrastructure planning and allocation are matters of policy to be determined by the State Higher Education Council, the Department of Higher Education, and the Government of Himachal Pradesh, in consultation with all relevant stakeholders.

Arguments by the Petitioners:

The petitioners, represented by Advocate Mr. Vivek Singh Attri, submitted that they enrolled with Sardar Patel University on the assurance that, in accordance with a Memorandum of Understanding (MoU), the University would conduct classes from the premises of Maharaja Lakshman Sen Memorial College. They claimed that the Director of Higher Education’s office communication directing the University to hand over the RUSA-funded building to Maharaja Lakshman Sen Memorial College was arbitrary, unreasonable, and contrary to their legitimate expectations. The students argued that this abrupt change in infrastructure location caused significant hardship, forcing them to travel to alternative locations farther from Sundernagar, thereby disrupting their academic schedule and causing financial and logistical inconvenience. They contended that the State authorities’ actions were detrimental to the interests of students who had chosen the University based on specific infrastructure promises, and thus violated the principles of fairness and reasonableness embedded in Article 14 of the Constitution of India. The petitioners further asserted that the authorities failed to consider their representation or provide an opportunity for consultation before taking a decision that directly affected their academic convenience and future prospects. In their view, public authorities exercising statutory powers must act transparently and avoid decisions that compromise students’ welfare, particularly when government policies like RUSA aim to strengthen infrastructure for higher education.

Arguments by the Respondents:

The respondents, represented by Additional Advocate General Mr. Pushpinder Jaswal for the State and other counsel for institutional stakeholders, opposed the petition, asserting that the students lacked locus standi to challenge a policy decision regarding infrastructure allocation. The State maintained that the establishment of the University, allocation of infrastructure, and related matters were policy decisions taken after deliberations involving the State Higher Education Council, Rashtriya Uchchatar Shiksha Abhiyan (RUSA), Department of Higher Education, Government of Himachal Pradesh, Maharaja Lakshman Sen Memorial Trust, and Maharaja Lakshman Sen Memorial College. These decisions, according to the respondents, are taken after considering factors such as resource optimization, accessibility, and long-term developmental goals for higher education in the State. The respondents argued that students cannot dictate where infrastructure should be established, as such interference would disrupt governance and planning mechanisms essential for managing universities. The State further pointed out that the Executive Council of Sardar Patel University itself approved the decision to hand over the building and that alternative infrastructure was arranged for the University to ensure continuity of classes. Therefore, no prejudice was caused to students, and their academic interests were safeguarded. The respondents stressed that judicial review of policy decisions is limited to cases of arbitrariness, malafides, or violation of fundamental rights, none of which were established by the petitioners in this case.

Court’s Judgment:

After hearing both sides, Justice Ajay Mohan Goel dismissed the petition, holding that the determination of where the infrastructure of a cluster university should come up lies exclusively within the domain of statutory and governmental authorities. The Court categorically stated that such decisions cannot be dictated by students based on personal convenience or expectations. Justice Goel observed:

 “This Court again reiterates that where the infrastructure of the Cluster University is to come up is the domain of the respondents and it is not for the petitioners to dictate the respondents as to where they should come up with their infrastructure.”

 The Court emphasized that infrastructure planning is a matter of policy, involving multiple stakeholders, financial considerations, and long-term objectives, and therefore cannot be subjected to judicial intervention at the behest of students dissatisfied with logistical changes. It further noted that the Executive Council of the University had already approved the decision and that alternative arrangements had been made for classes, ensuring no interruption to academic activities. Consequently, the Court found no merit in the petitioners’ claim that their rights were violated or that the authorities acted arbitrarily. Referring to established principles of judicial review, the Court underscored that courts cannot substitute their wisdom for that of the executive in matters of policy unless the decision suffers from arbitrariness, illegality, or malafides—none of which were demonstrated in this case. Accordingly, the writ petition was dismissed as devoid of merit.

Key Takeaways from the Judgment:

• Domain of Policy Decisions: Decisions on location and allocation of university infrastructure fall within the executive domain and are not subject to interference based on students’ preferences.
• Limited Scope of Judicial Review: Courts will not interfere in educational policy matters unless clear arbitrariness, malafides, or violation of fundamental rights is established.
• Locus Standi: Students have no enforceable right to dictate the location of university infrastructure, especially when academic continuity is ensured through alternative arrangements.
• Executive Council’s Approval: Internal governance bodies of universities have a decisive role in implementing policy directions, reinforcing institutional autonomy within statutory frameworks.

Impact of the Judgment:

The decision reinforces judicial restraint in matters of educational policy, reaffirming the principle that courts should not micromanage administrative decisions unless they infringe upon fundamental rights or are patently unreasonable. By dismissing the petition, the Court highlighted the necessity of respecting the autonomy of educational authorities and the State in planning infrastructure for long-term institutional development. For students, the judgment underscores the importance of adaptability and the recognition that convenience-based claims cannot override policy decisions taken in the collective interest of higher education governance.