A) ABSTRACT / HEADNOTE

The judgment examines the constitutional validity and statutory force of the UGC Revised Guidelines dated 06.07.2020 mandating conduct of final year/terminal semester examinations during the COVID-19 pandemic. The petitions raised an intense conflict between academic standardisation under central law and public health decisions taken by States under the Disaster Management Act, 2005. The Supreme Court was required to adjudicate whether the University Grants Commission acted within its statutory mandate under Section 12 of the UGC Act, 1956, whether the impugned guidelines violated Articles 14 and 21 of the Constitution, and whether State decisions cancelling final examinations could override UGC directions.

The Court reaffirmed the constitutional primacy of Entry 66, List I concerning coordination and determination of standards in higher education. It held that final year examinations form an integral component of academic standards and that UGC guidelines issued under Section 12 possess statutory force. While recognising the overriding authority of State Disaster Management Authorities to restrict physical examinations due to health exigencies, the Court drew a critical distinction between postponement of examinations and grant of degrees without examinations. The latter, it held, fell outside the jurisdiction of the Disaster Management Act.

The judgment carefully balances federal supremacy in educational standards with state autonomy in disaster response, carving out a nuanced legal position that preserves academic integrity while allowing flexibility in extraordinary circumstances.

Keywords:
UGC Guidelines; Final Year Examinations; Disaster Management Act; Entry 66 List I; Academic Standards; Articles 14 and 21

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The litigation emerged from an unprecedented disruption of the academic ecosystem caused by the COVID-19 pandemic. Nationwide lockdowns commencing 24.03.2020 rendered traditional university examinations impracticable. In response, the University Grants Commission, acting on expert committee recommendations, issued academic guidelines dated 29.04.2020, later revised on 06.07.2020, mandating completion of final year examinations by 30.09.2020 through offline, online, or blended modes.

Several States, particularly Maharashtra and West Bengal, invoked powers under the Disaster Management Act, 2005, deciding to cancel final examinations altogether and award degrees based on internal assessments. This divergence triggered a constitutional confrontation involving central academic authority, state disaster powers, and fundamental rights of students.

Multiple writ petitions under Article 32 challenged both the UGC guidelines and State decisions. Petitioners alleged violation of Articles 14 and 21, arbitrariness, health risks, and discrimination between final-year and intermediate students. Conversely, other petitioners sought enforcement of UGC directions against State cancellations.

The Court was therefore confronted with determining the hierarchy between central educational standards and state disaster responses, while safeguarding student welfare and constitutional discipline.

D) FACTS OF THE CASE

The petitioners were final-year undergraduate and postgraduate students across multiple States. Following pandemic-related disruptions, UGC constituted an Expert Committee which initially proposed examinations by 31.07.2020. Due to worsening conditions, revised guidelines extended the deadline to 30.09.2020 and permitted flexible examination modes.

On the same date, the Ministry of Human Resource Development issued a Standard Operating Procedure vetted by the Ministry of Health and Family Welfare. The Ministry of Home Affairs granted conditional exemptions for conducting examinations.

Despite this, State Disaster Management Authorities in Maharashtra and West Bengal resolved not to conduct final examinations, instead opting for promotion based on internal assessments. These State decisions directly conflicted with UGC directives.

Petitioners argued that universities were converted into COVID facilities, public transport was restricted, digital access was unequal, and examination mandates endangered life and health. Comparisons were drawn with cancellation of CBSE Class X and XII examinations.

UGC, supported by the Union, defended the guidelines as statutory, reasonable, and essential for maintaining academic standards. The States contended that disaster response powers under Section 72 of the Disaster Management Act prevailed.

E) LEGAL ISSUES RAISED

i. Whether the UGC Guidelines dated 06.07.2020 are statutory in nature under Section 12 of the UGC Act, 1956?
ii. Whether mandating final year examinations during COVID-19 violates Articles 14 and 21 of the Constitution?
iii. Whether State Disaster Management Authorities can cancel final examinations and promote students without exams?
iv. Whether Entry 66 List I overrides State decisions under the Disaster Management Act?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for Petitioners submitted that the revised guidelines were arbitrary and disregarded escalating COVID-19 risks. They argued that right to life and health under Article 21 was imperilled by compulsory examinations. Reliance was placed on the overriding clause under Section 72 of the Disaster Management Act. It was asserted that UGC failed to consult universities, rendering the guidelines ultra vires Section 12. Differential treatment between final-year and intermediate students was alleged to violate Article 14.

G) RESPONDENT’S ARGUMENTS

The counsels for Respondents contended that UGC is an expert statutory body entrusted with maintaining academic standards. Final examinations were integral to degree credibility. The guidelines were issued after expert consultation and provided flexibility, including special chances. The Union argued that State powers under the Disaster Management Act extended only to disaster mitigation, not academic evaluation or degree conferment.

H) RELATED LEGAL PROVISIONS

i. Article 14, Constitution of India
ii. Article 21, Constitution of India
iii. Entry 66, List I, Seventh Schedule
iv. Entry 25, List III, Seventh Schedule
v. Section 12, University Grants Commission Act, 1956
vi. Section 72, Disaster Management Act, 2005

I) JUDGMENT 

The Court held that UGC Guidelines dated 06.07.2020 are statutory, issued under Section 12, which expressly includes “examination” within its ambit. Academic standards necessarily encompass assessment mechanisms. Reliance was placed on Gujarat University v. Krishna Ranganath Mudholkar and Dr. Preeti Srivastava v. State of M.P..

The Court rejected Article 14 challenges, holding that final-year students constitute a distinct class. Final examinations provide an opportunity for academic improvement and career progression. Uniform deadlines further national academic coherence.

On Article 21, the Court noted that SOPs were vetted by health authorities and flexibility was built into examination modes. Hence, no violation was established.

Critically, while recognising that State Disaster Management Authorities may restrict physical exams, the Court held that promotion without examination falls outside the Disaster Management Act. The power to determine academic standards rests exclusively with UGC under Entry 66 List I.

However, the Court harmonised both regimes by holding that State decisions postponing exams override UGC deadlines, but cannot override the requirement of conducting examinations altogether.

a) RATIO DECIDENDI

The statutory authority of UGC under Section 12 of the UGC Act includes regulation of examinations as a core component of academic standards. State powers under the Disaster Management Act, 2005 do not extend to waiving mandatory examinations or granting degrees without assessment. Entry 66 List I constitutionally prevails over inconsistent State action.

b) OBITER DICTA

The Court observed that academic autonomy must yield neither to populism nor panic. Extraordinary situations require calibrated flexibility, not abandonment of standards. Consultation under Section 12 is contextual, not universal.

c) GUIDELINES ISSUED

i. States may postpone examinations under disaster powers.
ii. States cannot promote final-year students without examinations.
iii. UGC may extend deadlines upon State request.
iv. Universities must adopt flexible examination modes.

J) CONCLUSION & COMMENTS

The judgment is a meticulous exposition on cooperative federalism in education. It preserves academic integrity while respecting public health exigencies. The nuanced distinction between postponement and promotion without examination safeguards degree credibility. The ruling reinforces constitutional supremacy of Entry 66 without undermining disaster governance, setting a critical precedent for crisis-era education policy.

K) REFERENCES

a) Important Cases Referred

• Gujarat University v. Krishna Ranganath Mudholkar, [1963] Supp SCR 112

• Dr. Preeti Srivastava v. State of M.P., (1999) 7 SCC 120

• Professor Yashpal v. State of Chhattisgarh, [2005] 2 SCR 23

• University Grants Commission v. Neha Anil Bobde, (2013) 10 SCC 519

b) Important Statutes Referred

• University Grants Commission Act, 1956

• Disaster Management Act, 2005

• Constitution of India