Supreme Court Holds That a Student Cannot Be Denied Academic Documents Due to University’s Clerical Error in Admission Records

Case Name: Pratima Das v. State of Himachal Pradesh & Ors.
Citation: 2026 INSC 13
Date of Judgment/Order: 06 January 2026
Bench: Justice Vikram Nath and Justice Augustine George Masih

Held: The Supreme Court held that when a student is a bona fide enrollee who has cleared all examinations and whose name appears in the university’s primary records, academic documents cannot be withheld solely due to a clerical or inadvertent error committed by the university in its admission disclosure list, as such institutional lapses cannot be allowed to prejudice the student.

Summary: The appellant, a law graduate from Manav Bharti University, was denied her fifth to tenth semester marksheets and degree after records of the university were seized during investigation into allegations of fake degrees. Although her name appeared in the university’s green register and she had cleared all examinations, her documents were withheld on the ground that her name did not appear in the admission disclosure list forwarded by the university. Multiple proceedings, including a public interest litigation, failed to resolve her grievance. Before the Supreme Court, the university admitted through affidavit that the omission was a clerical error attributable to its previous administration and not to the appellant. The Court examined the record and found no factual dispute regarding the appellant’s bona fide admission and completion of the course.

Decision: The appeal was allowed, the impugned order of the High Court was set aside, and Manav Bharti University was directed to issue the appellant’s marksheets for the fifth to tenth semesters, her degree, and all other relevant academic documents within four weeks, with all pending applications disposed of.