Institution Cannot Claim Right to Earlier Academic Session Based on Erroneous PCI Approval When Mandatory Documents Were Submitted Beyond Prescribed Deadline; Supreme Court-Prescribed Timeline for B.Pharm. Course Approval Cannot Be Relaxed: Punjab & Haryana High Court
Case Name: Somany College of Pharmacy v. Pharmacy Council of India and Others
Date of Judgment: 15.10.2026
Citation: CWP-22228-2026
Bench: Justice Suvir Sehgal and Justice Rajesh Gaur
Held: The Punjab and Haryana High Court held that an educational institution cannot claim an enforceable right on the basis of an approval erroneously issued by the Pharmacy Council of India (PCI), particularly when mandatory statutory documents were not submitted within the prescribed cut-off date. The Court emphasised that the schedule approved by the Supreme Court for granting permission to commence pharmacy courses is binding upon the regulatory authority and cannot be relaxed merely because the institution subsequently fulfilled the requirements or underwent inspection. Correction of an inadvertent error in the approval communication does not confer any right upon the institution to seek approval for an earlier academic session.
Summary: The petitioner, Somany College of Pharmacy, challenged PCI’s amended decision dated 30.04.2026, whereby its approval to commence a B.Pharm. course with an intake of 60 students was shifted from the academic session 2026-27 to 2027-28. The institution contended that PCI had already granted approval for 2026-27 through its communication dated 14.04.2026 and could not subsequently alter the same without affording an opportunity of hearing.
PCI maintained that the original communication contained an inadvertent error, as the petitioner had failed to submit the mandatory consent of affiliation and State Government NOC within the prescribed timeline. The Court noted that the Supreme Court-approved schedule required submission of the application along with SIF and PERC before 1 November of the preceding year and statutory documents by 15 November in special circumstances. However, the petitioner submitted the requisite documents only on 25.02.2026.
Relying upon the Supreme Court-prescribed timeline in Parshavanath Charitable Trust and Others v. All India Council for Technical Education and Others, the Division Bench held that PCI was bound to adhere to the approved schedule. Subsequent compliance or inspection could not retrospectively validate approval for the earlier academic session. The Court also distinguished Narender Singh v. State of Haryana and Laxmi Saroj v. State of Uttar Pradesh, observing that those decisions concerned delayed submission of documents by candidates selected for government employment and were inapplicable to the present dispute.
Decision: The High Court upheld PCI’s amended decision granting approval for the academic session 2027-28, finding no illegality or arbitrariness in the correction of the earlier communication. The writ petition was dismissed.