Student Not Liable for University Clerical Error in Records: SC

Pratima Das Vs State of Himachal Pradesh And Ors. (Supreme Court of India)

Student Cannot Suffer for University’s Clerical Error: Supreme Court Orders Release of Mark Sheets and Degree

The Supreme Court held that a bona fide student cannot be deprived of her academic documents due to clerical mistakes committed by the University, particularly when there is no dispute regarding her admission, attendance, or successful completion of examinations. The appellant, a BA LL.B. graduate of Manav Bharti University (2017–2022 batch), was denied her 5th to 10th semester mark sheets and degree because her name did not appear in the admission disclosure list, even though it was duly reflected in the Green Register and other internal records.

During proceedings, the University categorically admitted on affidavit that the omission was caused by a purely inadvertent clerical error of the previous administration, whereby the name of another student was mistakenly forwarded in place of the appellant’s name. The Court noted that the appellant had cleared all semesters, was issued mark sheets for the first four semesters in the normal course, and that the discrepancy was entirely attributable to the University, not to any fault or misrepresentation by the student.

The Court held that relegating the appellant to further litigation, as directed by the High Court, was unnecessary and unjust, especially when the factual controversy stood conclusively resolved. Prolonged withholding of documents had caused serious prejudice to the appellant’s academic and professional future, including inability to enrol with the Bar Council or pursue higher studies.

Accordingly, the Supreme Court allowed the appeal and directed Manav Bharti University to issue the remaining semester mark sheets, degree, and all relevant documents within four weeks, reaffirming that students cannot be made to bear the consequences of administrative lapses of educational institutions.

FULL TEXT OF THE SUPREME COURT JUDGMENT/ORDER

1. Leave granted.