Introduction:
The Delhi High Court, in Harshit Agrawal v. National Testing Agency and Others (2026 LiveLaw (Del) 67), delivered a significant judgment reaffirming that the right to pursue higher or professional education forms an integral part of the constitutional guarantee of life and personal liberty, and cannot be curtailed lightly or on the basis of mere suspicion. Justice Jasmeet Singh held that although higher education is not expressly enumerated as a fundamental right under Part III of the Constitution, the State has an affirmative obligation to ensure that access to higher and professional education is not arbitrarily denied. The case arose in the backdrop of the NEET-UG 2024 examination controversy, where multiple admissions were cancelled following an investigation into alleged paper leaks. The petitioner, Harshit Agrawal, who had secured an All India Rank of 28,106 and General Category Rank of 11,234, had been admitted to the MBBS course at Bhima Bhoi Medical College and Hospital, Balangir, Odisha, strictly on the basis of merit. However, after his name appeared in a list of candidates under scrutiny, his scorecard was withdrawn and his admission cancelled, despite the Central Bureau of Investigation (CBI) later clarifying that he was not an accused but only a witness in the chargesheet. Aggrieved by the cancellation and disruption of his medical education, the petitioner approached the High Court seeking restoration of his admission and permission to attend classes, especially since another similarly placed candidate had been allowed by the Supreme Court to continue studies. The High Court, while allowing the petition, underscored that academic careers cannot be destroyed without concrete proof of wrongdoing, and that administrative action affecting education must meet the highest standards of fairness and legality.
Arguments:
On behalf of the petitioner, it was argued that his admission to the MBBS course was secured purely on merit, after clearing NEET-UG 2024, and that no material existed to suggest that he had indulged in any malpractice. It was submitted that the mere fact that the CBI had summoned him for questioning could not justify punitive action such as cancellation of admission, especially when the chargesheet did not name him as an accused. The petitioner contended that he had responded to the show-cause notice issued by the National Testing Agency (NTA), yet his scorecard was withdrawn without any reasoned order or finding of guilt, resulting in abrupt termination of his medical education. It was further argued that such action violated the principles of natural justice, proportionality, and fairness, and amounted to an arbitrary exercise of administrative power. Strong reliance was placed on the fact that another student whose name also appeared in the same suspected list was permitted by the Supreme Court to continue studies and appear in examinations, thereby entitling the petitioner to parity of treatment. The petitioner emphasized that denial of education, particularly professional medical education, causes irreversible academic and psychological harm, and therefore any such action must be based on compelling evidence, not conjecture or institutional anxiety arising from a larger investigation.
On the other hand, the respondents, including the NTA and concerned authorities, sought to justify their action by stating that the admission was cancelled pursuant to investigations into alleged irregularities in the NEET-UG examination. It was argued that once a candidate’s name appears in a list of suspected beneficiaries of malpractice, authorities are duty-bound to take preventive steps to preserve the integrity of the examination system. The respondents contended that issuance of summons by the CBI indicated the existence of suspicious circumstances, and therefore continuation of admission would undermine public confidence in the examination process. However, the CBI itself clarified before the Court that the petitioner was not named as an accused in the chargesheet and was only cited as a witness, and that there was no material showing his direct involvement in any wrongdoing. The State therefore attempted to justify its action on administrative caution rather than evidentiary culpability, urging the Court not to interfere with policy decisions taken to safeguard institutional credibility.
Court’s Judgment:
After hearing both sides, the Delhi High Court held that the action of cancelling the petitioner’s admission and withdrawing his scorecard was legally unsustainable and constitutionally impermissible. Justice Jasmeet Singh categorically observed that the right to pursue higher and professional education, though not expressly stated in Part III, flows from Article 21, and the State has a corresponding obligation to protect this right. The Court emphasized that such a valuable right, once earned through merit in a competitive national examination, cannot be taken away without valid, genuine, and compelling reasons supported by evidence. The Court took serious note of the CBI’s statement that the petitioner was not an accused, which, in the Court’s view, clearly demonstrated that there was no prima facie finding of malpractice attributable to him. In the absence of any material establishing wrongdoing, the cancellation of admission was held to be arbitrary and disproportionate.
The Court further observed that administrative decisions affecting academic careers must be guided by reason, fairness, and proportionality, and not by generalized suspicion arising out of a broader investigation. It held that the petitioner’s academic progress had been severely disrupted on totally unjustifiable grounds, and that such disruption could have long-term consequences on his professional future. The Court also found merit in the petitioner’s plea of parity, noting that when another similarly placed candidate was allowed by the Supreme Court to continue studies, denying similar relief to the petitioner would be discriminatory and inconsistent with constitutional principles of equality. Justice Singh made it clear that while the State is entitled to investigate examination malpractices and punish guilty persons, innocent candidates cannot be made collateral damage in such processes.
Accordingly, the High Court directed the concerned authorities to permit the petitioner to continue his MBBS classes in accordance with the prescribed curriculum, thereby restoring his academic status. The judgment reinforced that institutional credibility must be preserved through lawful investigation and prosecution of offenders, not by sacrificing the rights of students who are not even accused. By doing so, the Court reaffirmed that constitutional protections do not evaporate in the face of administrative convenience, and that education remains a core component of individual dignity and social mobility.