Ph.D. admission, UGC NET, JRF category, University of Rajasthan, merit list, interview score, writ petition, Rajasthan High Court, academic autonomy, regulatory framework
 30 Oct, 2026
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Ajay Yadav & Anr. Vs. University Of Rajasthan & Anr.

  Rajasthan High Court S.B. Civil Writ Petition No. 15786/2026
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Case Background

As per case facts, the petitioner, a meritorious Scheduled Tribe student who qualified UGC NET-JRF in Economics, challenged the University of Rajasthan's Ph.D. admission merit list. The University allegedly clubbed ...

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Document Text Version

[2026:RJ-JP:42065]

HIGH COURT OF JUDICATURE FOR RAJASTHAN

BENCH AT JAIPUR

S.B. Civil Writ Petition No. 15973/2026

CNR: RJHC020800092026 | URN: CW / 33980U / 2026

Yash Chandra S/o Shri Chandra Prakash Meena, Aged About 25

Years, Resident Of C-34 Bal Nagar, Kartarpura, Jaipur.

----Petitioner

Versus

1. State Of Rajasthan, Through The Principal Secretary,

Department Of Higher Education, Government Of

Rajasthan, Secretariat, Jaipur-302005

2. University Of Rajasthan, A Statutory University

Established Under The Rajasthan University Act, 1946,

Through Its Registrar, Having Its Office At University Of

Rajasthan Campus, Jln Marg, Jaipur-302004, Rajasthan

3. University Grants Commission, A Statutory Body

Constituted Under The University Grants Commission Act,

1956, Through Its Secretary, Having Its Office At Bahadur

Shah Zafar Marg, New Delhi-110002

4. National Testing Agency, Through Its Director General,

Block-C, 3Rd Floor, Institutional Area, Adjacent Iit Delhi,

New Delhi-110016, Being The Agency Conducting The

Ugc-Net Examination.

----Respondents

Connected With

S.B. Civil Writ Petition No. 15786/2026

CNR: RJHC020794002026 | URN: CW / 33637U / 2026

1. Ajay Yadav S/o Shri Rajendra Prasad Yadav, Aged About

27 Years, Resident Of Vpo Manksi, Tehsil Neema Ka

Thana, District Sikar-332711

2. Pradeep Kumar S/o Shri Mangtu Ram, Aged About 32

Years, Resident Of Post Deswala, Via. Nua, Khidasar,

(Peva Ki Dhani), Jhunjhunu-333001

----Petitioners

Versus

1. University Of Rajasthan, Through Registrar, Jln Marg

Jaipur

[2026:RJ-JP:42065] (2 of 20) [CW-15973/2026]

2. Department Of Law University Of Rajasthan, Through

Head Of The Department, Jaipur-302004

----Respondents

For Petitioner(s) : Dr. Rudranshu Singh, Amicus Curiae

Mr. Darsh Pareek

Mr. Tanveer Ahmed with

Ms. Akshita Sharma

For Respondent(s) : Mr. Vishnu Kant Sharma

HON'BLE MR. JUSTICE SAMEER JAIN

Judgment

1Arguments concluded on 13/10/2026

2Judgment Reserved on 13/10/2026

3Full Judgment or Operative Part Pronounced Full Judgment

4Pronounced on 30/10/2026

1.In view of the intertwined nature of the controversy involved,

coupled with the identical factual matrix emerging in the present

matters, and with the consent of the learned counsel representing

the respective sides, owing to the congruence of issues and for the

sake of expedient adjudication, the instant petitions are decided

by this common adjudicatory judgment, the ratio decidendi

whereof shall operate mutatis mutandis upon all related pleadings.

For the purposes of factual clarity and narrative convenience, the

averments articulated in SBCWP No. 15973/2026 are adopted by

this Court as the primary factual matrix for the disposal of the

instant lis.

BRIEF FACTS OF THE CASE :

2.The present writ petition has been filed by the petitioner, a

meritorious student belonging to the Scheduled Tribe (ST)

category, who has successfully qualified the UGC NET examination

[2026:RJ-JP:42065] (3 of 20) [CW-15973/2026]

in the subject of Economics and has been declared eligible for the

award of Junior Research Fellowship (hereinafter referred to as

“JRF”). The petitioner is aggrieved by the first merit list dated

10.08.2026 issued by respondent No. 1, University of Rajasthan,

for admission to its Ph.D. programme for the academic session

2025–2026 under the Rajasthan University Ph.D. Admission

Examination Scheme (hereinafter referred to as “RUPA”).

3.The preliminary alleged contention of the petitioner is that

the impugned merit list has been prepared in flagrant violation of

the University Grants Commission (Minimum Standards and

Procedure for Award of Ph.D. Degree) Regulations, 2022

(hereinafter referred to as “the Regulations of 2022”), and the

RUPA 2025 Information Bulletin, read with the corrigendum issued

thereto. It is averred that respondent No. 1 has clubbed together

candidates falling under Category 1, comprising JRF-qualified

candidates; Category 2, comprising NET-qualified candidates

eligible for appointment as Assistant Professors; and Category 3,

comprising candidates qualified in NET for Ph.D. admission only,

into a single common merit list, without adhering to the distinct

criteria applicable to the respective categories; despite the fact

that under the applicable provisions, candidates falling under

Categories 2 and 3 are required to be evaluated on the basis of a

combined weightage of 70% for the NET score and 30% for the

interview. However, respondent No. 1 has arbitrarily and without

any authority of law evaluated all candidates, including those

falling under Category 1, such as the petitioner, solely on the basis

of the marks obtained in the interview, thereby completely

[2026:RJ-JP:42065] (4 of 20) [CW-15973/2026]

disregarding the petitioner's NET/JRF score. It is, thus, alleged

that the merit of the petitioner and other similarly situated JRF-

qualified candidates, who otherwise possessed demonstrably

superior overall merit, has been ignored in the preparation of the

impugned merit list.

SUBMISSIONS ADVANCED BY THE LEARNED COUNSEL

APPEARING ON BEHALF OF THE PETITIONER :

4.At the outset, it was submitted by the learned counsel for

the petitioner that the Regulations of 2022 were notified on

07.11.2022 by the respondent number 3 and the same is binding

on all the universities including respondent number 2 i.e.

University of Rajasthan. It was submitted that Regulation 5 of the

said Regulations categorically prescribes the procedure for

admission to the PhD program. It was further submitted that on

13.03.2024 the UGC in its 578th meeting on the recommendation

of an expert committee decided that from the academic session

2024-2025 the NET score can be used for admission to PhD

programs in place of entrance test conducted by the individual

universities. Consequently on 27.03.2024 the UGC issued a public

notice classifying NET qualified candidates into three categories:

Category 1 comprising of JRF and assistant professors, Category 2

assistant professor and PhD admission only, and Category 3 PhD

admission only. It was contended that the JRF qualified, i.e.

Category number 1 candidates are to be admitted on the basis of

interview, while Category 2 and 3 candidates are to be admitted

on the combined merit comprising of 70% of the NET score and

30% of the interview.

[2026:RJ-JP:42065] (5 of 20) [CW-15973/2026]

5.It was further submitted that respondent No. 2, University of

Rajasthan, issued an advertisement inviting applications for

admission to its Ph.D. programme for the academic session 2025–

2026, along with the requisite Information Bulletin. Thereafter, a

corrigendum was issued, whereby Clause 6 of Section A of the

Information Bulletin was substituted to provide that candidates

seeking admission under the JRF category must possess a valid

JRF award for the period specified in the NET certificate. It was

submitted that the petitioner, having obtained the requisite

certificate, applied for admission under the RUPA Scheme, 2025,

on 28.07.2026 in the JRF category. The petitioner appeared for

the interview conducted by the Department of Economics of

respondent No. 2. Subsequently, on 10.08.2026, the Department

of Economics issued the first merit list for admission to the Ph.D.

programme. However, to the shock and dismay of the petitioner,

his candidature was rejected on the ground that he had failed to

secure the prescribed qualifying marks in the interview. It was

contended that candidates belonging to Categories 1, 2 and 3

were placed in a single common merit list, and their merit was

determined solely on the basis of the marks obtained in the

interview, in clear violation of the guidelines issued by the UGC.

6.It was further submitted that on 11.08.2026, i.e., the very

next day after publication of the first merit list, the petitioner

submitted a representation by way of email to the Vice-Chancellor

of the University of Rajasthan, bringing the aforesaid

discrepancies to the University's attention. However, no action was

taken on the said representation. Learned counsel for the

[2026:RJ-JP:42065] (6 of 20) [CW-15973/2026]

petitioner further submitted that as per the revised schedule for

Ph.D. admissions, the last date for depositing the admission fee by

demand draft by provisionally admitted candidates was

14.08.2026. In view of the imminent deadline and the grievance

raised by the petitioner, the present writ petition came to be filed,

and by an interim order dated 14.08.2026, this Court granted

provisional admission to the petitioner to the Ph.D. programme in

Economics under the JRF category.

7.Learned counsel for the petitioner stoutly submitted that the

petitioner had a legitimate expectation of being duly considered

for admission to the Ph.D. programme in accordance with the

applicable rules and guidelines, having qualified the UGC NET-JRF

examination and thereafter applied for admission and appeared in

the interview in conformity with the guidelines. It was contended

that the petitioner possessed demonstrably superior merit as

compared to the candidates whose names find place in the

impugned merit list and, therefore, had a legitimate expectation of

being selected in accordance with the prescribed admission

criteria. However, owing to the alleged misinterpretation and

erroneous application of the applicable rules and regulations,

culminating in the preparation of the impugned merit list, the

petitioner was denied admission despite his superior merit. It was

further contended that the admission criteria prescribed under the

RUPA 2025 Information Bulletin, as adopted by the University of

Rajasthan, are inconsistent with the public notice dated

27.03.2024 issued by the UGC, particularly with regard to the

methodology prescribed for the evaluation and selection of

[2026:RJ-JP:42065] (7 of 20) [CW-15973/2026]

candidates belonging to the three distinct NET categories. In this

regard, learned counsel for the petitioner advanced the following

submissions:

7.1 That under the UGC public notice dated 27.03.2024,

candidates falling under Categories 2 and 3 are required to be

assessed on the basis of a combined weightage of 70% for the

NET score and 30% for the interview. However, under the RUPA

2025 guidelines, only twice the number of candidates

corresponding to the available seats are called for the interview,

with such candidates being shortlisted solely on the basis of their

NET percentile. Therefore, the NET percentile operates as a

decisive screening criterion even before the prescribed 30%

weightage for the interview is applied, thereby raising concerns

regarding the manner in which the University's admission

procedure gives effect to the evaluation methodology stipulated by

the UGC.

7.2 That under the UGC framework, candidates qualified for

JRF, falling under Category 1, are to be considered for admission

on the basis of their performance in the interview. However,

Clause B(2) of the RUPA 2025 guidelines provides for calling

candidates for the interview on the basis of their percentile,

whereas Clause B(1) provides that admission is to be determined

on the basis of the test score obtained in the interview. It was

contended that these provisions, when read together with Clause

B(5)(i), which stipulates that candidates belonging to Category 1

are to be evaluated on the basis of the interview alone, give rise

to an apparent inconsistency within the University's own

[2026:RJ-JP:42065] (8 of 20) [CW-15973/2026]

admission framework. Thus, such inconsistency exposes JRF-

qualified candidates to a percentile-based cut-off, notwithstanding

that the methodology prescribed for their category under the UGC

public notice does not contemplate such an additional criterion for

determining their merit.

7.3 That the method prescribed under the RUPA 2025

guidelines for declaring and utilising the NET result for admission

is ambiguous. Learned counsel contended that the NET result is

required to be declared in terms of both marks and percentile so

that the relevant score may be utilised for the purpose of

admission. However, while the UGC framework prescribes a

weightage of 70% for the NET score and 30% for the interview in

the case of Categories 2 and 3, Clause B(5) of the RUPA 2025

guidelines refers to the score/percentile without clearly specifying

which of the two parameters is to be adopted for the purpose of

determining the final merit. Therefore, the guidelines do not

clearly prescribe the manner in which the NET score is to be

converted or accorded the stipulated weightage, nor do they

specify the method by which the marks obtained out of 100 in the

interview are to be scaled to correspond to the prescribed 30%

weightage. In the absence of a clear and unambiguous formula

governing such evaluation, the methodology adopted by the

University is alleged to be vague and uncertain, leaving the

process of preparation of the final merit list susceptible to

inconsistent interpretation.

8.Fourthly, it was contended that the respondents have not

prescribed any clear provision regarding the allocation or

[2026:RJ-JP:42065] (9 of 20) [CW-15973/2026]

distribution of seats among the three categories, nor have they

specified any inter se priority or preference to be accorded to

candidates belonging to the respective categories. Learned

counsel submitted that the NET score and the interview score

constitute distinct evaluation parameters and are not directly

comparable unless an appropriate and uniform methodology is

prescribed for their assessment. In the absence of clear rules

governing the comparative evaluation of candidates belonging to

different categories, the placement of all such candidates in a

common merit list, without adhering to the distinct selection

criteria applicable to each category, is arbitrary and contrary to

the framework contemplated by the UGC.

9.Learned counsel for the petitioner clarified that the petitioner

has not called into question the validity of the UGC scheme or the

relevant University ordinances. Rather, the grievance of the

petitioner is confined to the alleged failure of the respondents to

implement and enforce the applicable provisions in their true letter

and spirit. It is submitted that the UGC, by its public notice dated

27.03.2024, has expressly classified NET-qualified candidates into

three distinct categories and prescribed different admission

methodologies in recognition of the distinctions between the

qualifications and eligibility criteria applicable to such candidates.

Hence, the said classification and the corresponding evaluation

criteria have been consciously formulated by the UGC for valid

reasons and are required to be given effect to by the University

without amalgamating the distinct categories or disregarding the

methodology applicable to each of them. In support of the

[2026:RJ-JP:42065] (10 of 20) [CW-15973/2026]

submissions made insofar, learned counsel had placed reliance

upon a catena of judgments, inter alia, Dr. S. Mohan vs. The

Secretary to the Chancellor, Puducherry Technological University &

Ors.: 2026 INSC 100; Krishna Rai (Dead) Through Lrs & Ors. Vs.

Banaras Hindu University Through Registrar & Ors.: (2022) 8 SCC

713; Parmender Kumar & Ors. Vs. State of Haryana & Ors. :

(2012) 1 SCC 177; Visvesaraya Technological University & Anr.

Vs. Krishnendu Halder & Ors.: (2011) 4 SC 606; Professor Dr.

Sreejith PS Vs. Dr. Rajasee MS & Ors.: 2022 INSC 1137;

Annamalai University Vs. Secretary to Government, Information &

Tourism Dept. & Ors.: (2009) 4 SCC 590; Mandeep Singh Vs.

State of Punjab & Ors.: 2025 INSC 834; Divyot Sekhon Vs. State

of Punjab & Ors.: 2026 INSC 26; Tej Prakash Pathak & Ors. Vs.

Rajasthan High Court: (2025) 2 SCC 1; K. Manjusree Vs. State of

Andhra Pradesh & Anr.: (2008) 3 SCC 512.

10.On the aforesaid grounds, and the judgments as relied upon,

learned counsel for the petitioner submitted that the impugned

merit list has been prepared by adopting an allegedly inconsistent

and legally impermissible method of evaluation, thereby defeating

the prescribed admission framework and prejudicing the

petitioner's claim for admission despite his qualification under the

JRF category. Thus, appropriate directions are warranted to ensure

that the petitioner's candidature is considered in accordance with

the applicable UGC Regulations, the public notice dated

27.03.2024 and the relevant provisions of the RUPA 2025

guidelines.

[2026:RJ-JP:42065] (11 of 20) [CW-15973/2026]

SUBMISSIONS ADVANCED BY THE LEARNED COUNSEL

APPEARING ON BEHALF OF THE RESPONDENTS :

11.Per contra, learned counsel for the respondents submitted

that the petitioner had been called for an interview on 28.07.2026

in accordance with the Ph.D. admission schedule uploaded by the

Head of the Department of Economics. It was contended that,

upon completion of the selection process, the merit list had been

prepared strictly in accordance with the criteria prescribed under

Rule 5.4 of Ordinance 124 governing admissions to the Ph.D.

programme. The respondents maintained the selection process

and the same had been conducted in accordance with the

applicable rules and the prescribed procedure, and that no

illegality or irregularity could be attributed to the preparation of

the impugned merit list.

12.Learned counsel for the respondents further submitted that

no separate quota or reservation of seats had been prescribed for

candidates falling under Categories 1, 2 and 3, respectively. It was

contended that the seats had been allocated discipline-wise and

that the relevant seat matrix had been published by the University

in advance. Accordingly, the admission process had been

undertaken on the basis of the available seats in the respective

disciplines and the selection criteria prescribed by the University,

without any separate category-wise allocation of seats for the

aforesaid categories of NET-qualified candidates. It was further

contended that the petitioner had not challenged the validity of

the basic Regulations governing the admission process and,

therefore, could not seek to question the selection procedure

[2026:RJ-JP:42065] (12 of 20) [CW-15973/2026]

adopted by the University while leaving the underlying regulatory

framework unchallenged. Thus, the present writ petition is not

maintainable.

13.Learned counsel for the respondents also submitted that the

petitioner had voluntarily participated in the selection process,

appeared for the interview and subjected himself to the procedure

prescribed by the University. Having participated in the process,

the petitioner could not subsequently challenge its validity merely

because he had not been selected. It was contended that an

unsuccessful candidate could not, solely on account of an

unfavourable outcome, seek to invalidate the entire selection

process in the absence of any demonstrable illegality or violation

of the applicable rules. Lastly, it was submitted that the petitioner

had no vested right to seek a change in the mode or methodology

of selection adopted by the University. Learned counsel contended

that the determination of the admission procedure, the

formulation of the selection criteria and the manner in which

candidates were to be evaluated fell within the domain of the

University, subject to the governing statutory and regulatory

framework. It was argued that the petitioner could not insist upon

the adoption of a particular mode of selection merely because it

might have resulted in a more favourable outcome for him. In

support of the submissions made, learned counsel had relied upon

the ratio encapsulated in Edulanti Kistamma (Dead) thr. LRs.

And ors. v. S. Venkatareddy (Dead) thr. LRs. And ors. : AIR

2010 SC 313, Ramesh Chandra Shah and ors. v. Anil Joshi :

(2013) 11 SCC 309 and Taniya Malik V. The Registrar

[2026:RJ-JP:42065] (13 of 20) [CW-15973/2026]

General of the High Court of Delhi : 2018 INSC 168.

Accordingly, the respondents sought dismissal of the writ petition,

contending that the selection process had been conducted in

accordance with the prescribed procedure and that no interference

by this Court was warranted.

DISCUSSION AND FINDINGS :

14.Upon consideration of the submissions advanced by learned

counsel for the parties, the material available on record and the

applicable statutory and regulatory framework, this Court finds

that the controversy arising in the present petition lies within a

narrow compass, namely, whether the University of Rajasthan was

justified in preparing a common merit list for candidates falling

under Categories 1, 2 and 3 of the UGC NET classification and

determining their merit solely on the basis of interview marks,

without giving effect to the distinct admission methodology

applicable to the respective categories.

15.At the outset, this Court places on record its appreciation for

the valuable assistance rendered by learned Amicus Curiae –

Dr. Rudranshu Singh, whose erudite submissions and able

assistance have greatly facilitated the Court in adjudicating the

issues involved in the present matter. The Court acknowledges the

diligent efforts undertaken by learned Amicus Curiae in elucidating

the relevant statutory provisions and the applicable legal

principles, thereby assisting the Court in arriving at an informed

and considered determination. The Court expresses its gratitude

to learned Amicus Curiae for the assistance rendered.

[2026:RJ-JP:42065] (14 of 20) [CW-15973/2026]

16.Qua the merits/demerits of the case, it is necessary to

observe that the autonomy enjoyed by a university in academic

matters is not absolute or unfettered. Such autonomy must be

exercised within the bounds of the governing statutory provisions

and binding regulations framed by the competent authority. The

University Grants Commission (Minimum Standards and Procedure

for Award of Ph.D. Degree) Regulations, 2022, and the subsequent

public notice dated 27.03.2024, therefore, assume significance in

determining the legality of the admission procedure adopted by

the respondents.

17.In the ratio encapsulated in Annamalai University v.

Secretary to Government, Information and Tourism

Department : (2009) 4 SCC 590, the Hon'ble Supreme Court

emphasised the binding character of the UGC framework and held,

in substance, that mandatory requirements prescribed under the

governing regulatory legislation could not be disregarded or

rendered ineffective by action taken under another statutory

framework. The aforesaid judgment reinforces the principle that

institutional autonomy cannot be exercised in derogation of

binding regulatory requirements.

18.Applying the aforesaid principles to the facts of the present

case, this Court finds that the UGC public notice dated 27.03.2024

classified NET-qualified candidates into three distinct categories,

namely, Category 1, comprising candidates qualified for JRF and

appointment as Assistant Professor; Category 2, comprising

candidates qualified for appointment as Assistant Professor and

admission to Ph.D. programmes; and Category 3, comprising

[2026:RJ-JP:42065] (15 of 20) [CW-15973/2026]

candidates qualified for admission to Ph.D. programmes only.

According to the petitioner's case, the said notice contemplated

different admission methodologies for these categories, with

Category 1 candidates being assessed on the basis of interview

performance and Category 2 and Category 3 candidates being

evaluated on the basis of a combined weightage of 70% for the

NET score and 30% for the interview. For the sake of handiness

the relevant extract from the public notice dated 27.03.2026 is

reproduced hereinbelow:

“The determination of the eligibility of NET for different

categories is summarised below:

Qualified for Eligible for

JRF Assistant

Professor

PHD Admission

Category-1:

Award of JRF and

appointment as Assistant

Yes Yes Yes

Category-2: Appointment

as Assistant Professor and

admission to PHD

No Yes Yes

Category-3:

Admission to PHD only

No No Yes

The result of NET will be declared in percentile along

with the marks obtained by a candidate to utilise the

marks for admission to PhD.

The JRF-qualified students are admitted into the PhD

programme based on an interview as per the University

Grants Commission (Minimum Standards and

Procedures for PhD Degree) Regulations, 2022.

For students who qualify in Categories 2 and 3, 70%

weightage will be given for test scores and 30%

weightage for the interview for admission to PhD

programmes. The PhD admission will be based on the

[2026:RJ-JP:42065] (16 of 20) [CW-15973/2026]

combined merit of NET marks and the marks obtained

in the Interview/viva voce.”

19.The distinction between these categories cannot be treated

as merely descriptive or incidental. Where a competent regulatory

authority has prescribed distinct categories accompanied by

different evaluation methodologies, the authority entrusted with

implementing the admission process is required to give due effect

to such distinction. The expression generalia specialibus non

derogant, which signifies that a general provision does not

ordinarily override a special provision dealing with a specific

subject, may appropriately guide the interpretation of the

University's general admission provisions vis-a-vis the category-

specific requirements, provided that the latter are found to be

applicable and binding in the circumstances of the case.

20.Consequently, the absence of a separate category-wise quota

or allocation of seats, as contended by the respondents, does not,

by itself, resolve the controversy. The allocation of seats and the

determination of merit are distinct aspects of the admission

process. A common pool of seats may exist without necessarily

requiring candidates belonging to different eligibility categories to

be evaluated through an identical methodology, where the

governing framework prescribes otherwise. The respondents were

therefore required to demonstrate that the procedure adopted

under Rule 5(iv) of Information Bulletin and 5.4 of the Ordinance

124 (Annexure 7) was consistent with the applicable UGC

requirements and did not nullify the distinction recognised by the

[2026:RJ-JP:42065] (17 of 20) [CW-15973/2026]

UGC. For the sake of handiness the relevant extract from the

Information Bulletin is reproduced hereinbelow:

“5. The final merit list shall be prepared by the

respective department based on the following criteria:

(i) to (iii) xxx xxx xxx

(iv) The Interview Score shall be 100 marks, and the

Scheme of the interview shall be as provided under

Table 1 of Clause 5.2.

Qualification For Marks Obtained (in

NET or Equivalent

National Test)

Interview Total

Score

Category – I

Candidates who

qualify for similar

National level tests

fellowship/scholarship

in UGC-NET /UGC-

CSIR NET/GATE/CEED

and and similar

National level tests

Not applicable 100%

weightage to

Interview

Score

100

Category-II

Candidates who are

eligible for (I)

admission to PhD

without JRF and (ii)

appointment as

Assistant Professor.

70% weightage of

score/percentile

obtained in the UGC-

NET/UGC-CSIRNET

/GATE CEED and

similar National level

tests

30%

weightage to

Interview

Score

100

Category-IIII

Candidates are eligible

for

admission to the PhD

Programme only, and

not for the award of

JRF or appointment as

Assistant Professor

70% weightage of

score/percentile

obtained in the UGC-

NET/UGC-CSIRNET

/GATE CEED and

similar National level

tests

30%

weightage to

Interview

Score

100

21.This Court is also conscious of the settled principle that

judicial interference in academic matters must be exercised with

due restraint. Nevertheless, such restraint cannot be construed as

an exemption from compliance with statutory or regulatory

requirements. The issue before this Court is not whether the

[2026:RJ-JP:42065] (18 of 20) [CW-15973/2026]

University's academic assessment ought to be substituted by the

Court's own assessment, but whether the selection procedure

adopted by the University conformed to the applicable regulatory

framework. The distinction is material; judicial review does not

ordinarily extend to re-evaluating academic merit, but it does

extend to examining whether the authority concerned acted within

the limits of its legal powers and applied the prescribed criteria

uniformly and lawfully.

22.The respondents' contention that the petitioner had

participated in the selection process and could not subsequently

challenge it merely because he remained unsuccessful also

requires consideration in this context. However, the aforesaid

principle cannot be applied mechanically without examining the

nature of the challenge raised. In the present case, the petitioner

has not sought to invalidate the UGC Regulations or the

University's Ordinance on the ground that the prescribed criteria

are inherently unreasonable. Rather, his grievance is that the

respondents failed to implement the applicable regulatory

framework in the manner contemplated therein. The petitioner

had participated in the interview and, immediately upon

publication of the merit list dated 10.08.2026, submitted a

representation by email to the Vice-Chancellor on 11.08.2026. The

present challenge, therefore, is directed against the legality of the

implementation of the admission criteria and not merely against

an unfavourable assessment of the petitioner's interview

performance.

[2026:RJ-JP:42065] (19 of 20) [CW-15973/2026]

23.Accordingly, the principle of waiver or acquiescence cannot,

by itself, foreclose judicial examination of an allegation that an

admission authority has acted contrary to binding regulatory

provisions. Participation in a selection process does not confer

upon an authority the power to disregard mandatory legal

requirements, nor does it necessarily validate an otherwise

unlawful procedure.

24.This Court further finds that the petitioner's claim cannot be

rejected merely on the ground that he possesses no vested right

to admission. It is undoubtedly true that qualification in the UGC

NET-JRF examination does not, by itself, confer an automatic or

indefeasible right to secure admission to a Ph.D. programme. The

petitioner nevertheless possesses the right to have his candidature

considered in accordance with the eligibility conditions and

evaluation methodology lawfully applicable to his category. The

distinction is between claiming an unconditional right to admission

and claiming a lawful and fair consideration for admission. The

latter claim is amenable to judicial scrutiny where non-compliance

with binding rules is established.

25.In view of the foregoing discussion, this Court is of the

considered opinion that the impugned merit list cannot be

sustained if, as alleged and borne out by the applicable provisions,

the respondents have placed candidates belonging to all three

categories in a common merit list and evaluated them exclusively

on the basis of interview marks, without adhering to the distinct

admission methodology prescribed for the respective categories.

The respondents' reliance upon the absence of a category-wise

[2026:RJ-JP:42065] (20 of 20) [CW-15973/2026]

quota and upon the petitioner's participation in the selection

process does not, in itself, answer the central question concerning

compliance with the governing regulatory framework.

26.Consequently, the writ petitions are allowed. The impugned

merit list dated 10.08.2026 is hereby quashed and set aside

insofar as it affects the petitioner's candidature. The respondents

are directed to reconsider the petitioner's candidature for

admission to the Ph.D. programme in Economics under the JRF

category in accordance with the applicable UGC Regulations, the

public notice dated 27.03.2024, and the RUPA 2025 Information

Bulletin, read with the corrigendum issued thereto.

27.The respondents shall undertake the requisite exercise by

applying the evaluation methodology legally applicable to the

petitioner's category. In undertaking such exercise, the

respondents shall also ensure that the applicable criteria are

interpreted consistently with the governing regulatory framework.

28.The provisional admission granted to the petitioner pursuant

to the interim order dated 14.08.2026 shall abide by the outcome

of the aforesaid exercise and the consequential decision taken by

the respondents in accordance with law.

29.No orders are passed as to costs. Pending applications, if

any, shall stand disposed.

30.A copy of the present judgment be separately placed in the

connected petition.

(SAMEER JAIN),J

Preeti Asopa

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