A) ABSTRACT / HEADNOTE

This case examines the exercise of the Supreme Court’s power under Article 142 of the Constitution of India to do substantial justice. The petitioner, a Scheduled Caste (SC) student, lost his IIT admission in Electrical Engineering due to a delay of a few minutes in fee payment despite fulfilling all other requirements. The petitioner, a talented student from a marginalized community, secured a seat at IIT Dhanbad through hard-earned efforts. The Court, recognizing his earnestness and the injustice caused by the rigid application of timelines, granted relief by directing IIT Dhanbad to admit him. A supernumerary seat was created, ensuring no disturbance to other students. The case reaffirms the judiciary’s role in ensuring equity and access to education for underprivileged individuals.

Keywords: Scheduled Caste student, IIT admission, Article 142, marginalized communities, supernumerary seat.

B) CASE DETAILS

i. Judgment Cause Title: Atul Kumar v. The Chairman (Joint Seat Allocation Authority) and Others
ii. Case Number: Writ Petition (Civil) No. 609 of 2024
iii. Judgment Date: September 30, 2024
iv. Court: Supreme Court of India
v. Quorum: Dr. Dhananjaya Y Chandrachud, CJI, J B Pardiwala, and Manoj Misra, JJ.
vi. Author: Dr. Dhananjaya Y Chandrachud, CJI
vii. Citation: [2024] 10 S.C.R. 150
viii. Legal Provisions Involved:

• Article 142 of the Constitution of India
• Relevant administrative regulations governing IIT admission processes.
  ix. Judgments Overruled by the Case: None.
  x. Law Subjects: Constitutional Law, Educational Law, Administrative Law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The petitioner, Atul Kumar, a meritorious candidate, secured rank 1455 in the SC category in JEE Advanced 2024. Coming from a financially disadvantaged background, his family’s income was below the poverty line. The petitioner was allotted a seat at IIT Dhanbad in the Electrical Engineering branch. Due to technical issues and financial constraints, he failed to process the payment by a narrow margin before the portal’s deadline. Denied admission, he sought relief under Article 32, claiming violation of his fundamental rights.

D) FACTS OF THE CASE

1. Meritorious Candidate: The petitioner, hailing from a marginalized community, attempted admission under the SC category.
2. Background: This was his second and final permissible attempt under IIT regulations.
3. Fee Payment Deadline: The fee payment portal closed at 5:00 PM on June 24, 2024. The petitioner attempted payment at 4:45 PM, but the transaction did not complete before the deadline.
4. Efforts to Rectify: The petitioner contacted the Joint Seat Allocation Authority and various IITs, but his grievances remained unresolved.
5. Legal Recourse: Directed by legal aid services, he approached the Supreme Court for redress.

E) LEGAL ISSUES RAISED

1. Whether the rigid enforcement of the deadline violated the petitioner’s rights under Articles 14 and 21 of the Constitution.
2. Whether the Court can invoke Article 142 to ensure justice for a marginalized student.
3. Whether creating a supernumerary seat is a permissible remedy under IIT regulations.

F) PETITIONER/APPELLANT’S ARGUMENTS

The petitioner’s counsel argued:

1. Unjust Denial: The petitioner fulfilled all requirements and could not complete payment due to circumstances beyond his control.
2. Constitutional Rights: Denial of admission violated his right to equality (Article 14) and right to education as part of the right to life (Article 21).
3. Earnest Efforts: Login logs showed the petitioner’s consistent attempts to access the portal, indicating his commitment to securing admission.
4. Impact of Denial: The petitioner would lose his educational opportunity despite merit and diligent efforts.
5. Role of Judiciary: The Court’s intervention was necessary to correct a procedural injustice and uphold principles of substantial justice.

G) RESPONDENT’S ARGUMENTS

The respondents submitted:

1. Regulatory Compliance: IIT admission processes are governed by strict timelines to ensure administrative efficiency and fairness.
2. Portal Mechanism: The petitioner failed to process the payment within the stipulated time, despite opportunities.
3. Precedential Impact: Granting relief would set an unwelcome precedent, affecting the rigor of admission deadlines.

H) RELATED LEGAL PROVISIONS

1. Article 142, Constitution of India: Empowers the Court to do “complete justice” in cases before it.
2. Article 14 and Article 21: Right to equality and the right to life, including education.

I) JUDGMENT

Ratio Decidendi

1. Substantial Justice: The Court invoked Article 142 to ensure that a meritorious and marginalized student was not denied education due to procedural rigidity.
2. Log-In Evidence: Records showed the petitioner’s genuine and timely attempts to process his admission.
3. Equity over Rigidity: The Court emphasized the need to balance administrative timelines with social justice objectives.

Obiter Dicta

The judgment highlighted the need for institutions to adopt more flexible and equitable admission processes to account for technical and financial constraints faced by underprivileged students.

Guidelines Issued

1. The petitioner was admitted to IIT Dhanbad on a supernumerary seat.
2. The IIT was directed to accommodate the petitioner in the ongoing academic batch without disrupting other students.
3. The petitioner would receive support to cover the academic backlog.

J) CONCLUSION AND COMMENTS

The judgment underscores the judiciary’s role in mitigating systemic inequities and ensuring access to education for marginalized groups. It establishes a precedent for using Article 142 in cases of procedural lapses with severe consequences for deserving individuals.

REFERENCES

1. Constitution of India.
2. JEE Advanced Guidelines.
3. Supreme Court Judgment Database: 2024 INSC 749.