A) ABSTRACT / HEADNOTE

The Supreme Court examined whether the National University of Juridical Sciences (Amendment) Act, 2018, which introduced mandatory reservation of at least thirty percent seats for candidates domiciled in West Bengal, could be applied to an ongoing admission process for the academic session 2019–2020 conducted through Common Law Admission Test (CLAT). The appellant, having participated in CLAT after the amendment came into force, claimed entitlement to domicile reservation for the same academic year. The University declined such benefit, contending that the admission process had commenced prior to the amendment and that applying the new reservation would disturb the settled selection framework.

The Court analysed the statutory silence regarding the academic year from which reservation was to operate, the chronology of the admission process, and the administrative resolutions passed by the Academic Council and Executive Council of the University. The Court reaffirmed the doctrine that rules governing selection cannot be altered mid-process, unless expressly mandated by statute. It held that the amendment was prospective in operation and that the University’s decision to implement reservation from the next academic year was fair, reasonable, and non-arbitrary. Prior judgments relating to wrongful denial of admission and change of rules mid-selection were distinguished on facts. The appeal was dismissed.

Keywords: Reservation, Prospectivity, Admission Process, CLAT, Domicile Quota, Change of Rules

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The litigation arose in the context of the evolving framework of reservation policies in National Law Universities and their intersection with centrally conducted admission mechanisms like CLAT. The West Bengal National University of Juridical Sciences Act, 1999 was amended in 2018 to mandate compulsory domicile-based reservation. However, the amendment was notified only in May 2019, after the initiation of the admission cycle for the academic year 2019–2020.

The appellant sought to leverage the timing of the amendment vis-à-vis the CLAT examination date to claim immediate benefit of reservation. This raised a fundamental legal question regarding temporal applicability of statutory amendments, particularly in admission processes governed by predefined timelines and national-level coordination.

The High Court of Calcutta rejected the appellant’s claim, applying the principle against changing rules midstream. The Supreme Court was thus called upon to balance statutory intent, administrative practicality, and equitable treatment of candidates. The dispute implicated doctrines of prospective operation, legitimate expectation, and administrative fairness.

D) FACTS OF THE CASE

The appellant applied for admission to the five-year integrated law programme at the respondent University through CLAT 2019. The admission notification was issued in January 2019, well before the amendment came into force. At that time, only ten seats were earmarked for West Bengal domicile candidates.

The Amendment Act was published on 21 May 2019, mandating at least thirty percent reservation. The CLAT examination was conducted on 26 May 2019. The appellant secured All India Rank 731 and was allotted a seat at National Law University, Odisha, which he declined.

The University finalised admissions by July 2019 based on the pre-existing seat matrix. Subsequently, the Academic Council resolved to implement the new reservation from the next academic year, a decision approved by the Executive Council.

The appellant challenged this decision, alleging denial of statutory benefit despite the amendment being in force before the examination date. The University justified its stance citing disruption of the admission process and absence of statutory mandate for retrospective application.

E) LEGAL ISSUES RAISED

i. Whether the National University of Juridical Sciences (Amendment) Act, 2018 applies to an admission process already initiated prior to its commencement?
ii. Whether denial of domicile reservation for the academic year 2019–2020 violates statutory or constitutional guarantees?
iii. Whether implementing reservation from the next academic year amounts to arbitrariness?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellant submitted that the amendment “came into force at once” and was binding on the University. Since CLAT was conducted after 21 May 2019, the University was obligated to apply the amended reservation policy.

Reliance was placed on S. Krishna Sradha v. State of Andhra Pradesh, asserting that a meritorious candidate wrongfully denied admission should be accommodated in the subsequent academic year. It was argued that refusal amounted to changing statutory obligations under administrative convenience.

G) RESPONDENT’S ARGUMENTS

The counsels for the respondent contended that the admission process commenced in January 2019 and candidates exercised choices based on the then-prevailing reservation framework. Applying the amendment mid-cycle would disturb the entire national allocation process.

It was argued that the amendment was prospective and silent on applicability to ongoing admissions. The University’s resolution to apply it from the next academic year was reasonable and aligned with administrative law principles.

H) RELATED LEGAL PROVISIONS

i. Section 4A(3), West Bengal National University of Juridical Sciences Act, 1999
ii. Section 4B, West Bengal National University of Juridical Sciences Act, 1999
iii. Doctrine against changing rules of the game mid-process

I) JUDGEMENT 

The Supreme Court upheld the University’s decision. It held that the Amendment Act did not specify the academic year of implementation. The admission process had already crystallised before the amendment came into force.

The Court emphasised that reservation matrices must be finalised at the initiation of admissions. Applying new quotas mid-process would prejudice other candidates and undermine fairness. The resolutions passed by the Academic and Executive Councils were held to be reasonable and within statutory discretion.

a) RATIO DECIDENDI

The ratio rests on the principle that statutory amendments affecting selection criteria operate prospectively unless expressly stated otherwise. Silence in the statute regarding retrospective application implies legislative intent against disturbing settled processes.

The Court reaffirmed that administrative decisions taken to preserve fairness and certainty cannot be invalidated merely because a statute comes into force mid-cycle. The doctrine against changing rules mid-selection was determinative.

b) OBITER DICTA

The Court observed that the expression “at once” in commencement clauses does not necessarily mandate instantaneous operationalisation across all ongoing processes. Reasonable administrative implementation is permissible, particularly in large-scale national admissions.

c) GUIDELINES

i. Reservation policies must be implemented from the start of an admission cycle.
ii. Statutory silence on temporal application implies prospectivity.
iii. Universities must avoid mid-cycle alterations that disrupt candidate expectations.

J) CONCLUSION & COMMENTS

The judgment reinforces administrative stability in higher education admissions. It balances statutory interpretation with practical governance, ensuring predictability in national-level entrance systems. The ruling affirms that equity lies not in individual hardship but in systemic fairness.

K) REFERENCES

a. Important Cases Referred

i. S. Krishna Sradha v. State of Andhra Pradesh, [2019] 15 SCR 93
ii. Anupal Singh v. State of U.P., (2020) 2 SCC 173
iii. P. Bhima Reddy v. State of Mysore, [1969] 3 SCR 14

b. Important Statutes Referred

i. West Bengal National University of Juridical Sciences Act, 1999
ii. National University of Juridical Sciences (Amendment) Act, 2018