1. This Writ Petition is filed by the petitioner seeking the following relief:

               “to issue a Writ of Mandamus, or any other appropriate writ, order or direction and, (i) Quash the decision/ recommendation of the Respondent No. 1 dated 23/04/2026 directing the Petitioner to take a forced academic break and conditioning his return upon his being able to reside on campus independent of any assistance, (ii) Direct Respondent No. 1 to promote the Petitioner to the fourth year (Semester VII) of the B.A., LL.B. (Hons.) programme for the academic year 2026-27 and permit him to attend the classes of the fourth year by online mode and permit him to clear his pending courses through the repeat / re-registration mechanism, and (iii) Direct Respondent No. 2 to continue the Petitioners scholarship under the National Fellowship and Scholarship for Higher Education of Scheduled Tribe Students for the academic year 2026-27 and the remainder of the Petitioners course, (iv) Pass such other and further order(s) as this Honourable Court may deem fit and proper in the facts and circumstances of the case and in the interests of justice.”

02. Heard Sri Pradyuman Kaistha, learned counsel, representing Sri K. Harshitha Reddy, learned counsel for the petitioner and Sri A. Kranthi Kumar Reddy, learned Standing Counsel for National Academy of Legal Studies and Research (NALSAR) University of Law appearing for the respondent and perused the record.

03.1. Learned counsel for the petitioner submitted that the present writ petition has been filed questioning the action of the respondent-University in debarring the petitioner from academic progression on the ground of shortage of attendance and the consequential threat to his scholarship under the National Fellowship & Scholarship for Higher Education of Scheduled Tribe Students, administered by the 2nd respondent. He submits that the petitioner seeks, inter alia, a direction to the 2nd respondent to continue the scholarship being extended to the petitioner for the academic year 2026-27 and to set aside the decision of the 1st respondent dated 23.04.2026, whereby the petitioner has effectively been compelled to take an academic break and his return to the course has been made conditional upon his being able to reside on the University campus without assistance.

               03.2. It is further submitted that the petitioner is a 20-year-old student pursuing the five-year integrated B.A., LL.B. (Hons.) programme at the 1st respondent-University, a premier National Law University, and was admitted to the said programme in the year 2023 under Roll No.2023-5LLB-137. He further submitted that the petitioner has successfully completed the first two years of the programme and has otherwise maintained a commendable academic record.

               03.3. It is further submitted that the petitioner belongs to a Scheduled Tribe community and comes from an economically disadvantaged background. His father, who was working as Chief Manager in the Bank of Baroda, voluntarily retired from service in the year 2020, while his mother is a homemaker. The petitioner's education is substantially dependent upon the scholarship granted under the National Fellowship & Scholarship for Higher Education of Scheduled Tribe Students administered by the 2nd respondent.

               03.4. It is further submitted that the petitioner is a student of demonstrated academic merit. He secured 89.5% marks in the ICSE Class X examination and 92.5% marks in the ISC Class XII examination. He thereafter qualified in the Common Law Admission Test (CLAT) with an overall rank of 3375 and secured an All-India rank of approximately 15 among candidates belonging to the Scheduled Tribe category, pursuant to which he secured admission to the 1st respondent-University.

                03.5. It is further submitted that, apart from his academic performance, the petitioner has made meaningful contributions to the institutional life of the University. In particular, he was actively associated with and served as the Head of the Animal Welfare Initiative functioning under the University's Animal Law Centre. The said initiative undertakes, inter alia, the humane management and welfare of community dogs residing on the University campus. It is further submits that the significance of the said initiative is also reflected in the proceedings of the Hon'ble Supreme Court of India in In Re: 'City Hounded By Strays, Kids Pay Price', S.M.W. (C) No.5 of 2025, wherein the NALSAR campus model of stray-dog management was specifically noticed and commended as a model capable of being emulated by other educational institutions.

               03.6. It is further submitted that the attendance shortfall for which the petitioner has been debarred from academic progression was not deliberate or attributable to any lack of interest in pursuing his studies. According to the petitioner, the shortage of attendance arose on account of his mental illness and the difficulties associated with his condition, which materially affected his ability to attend classes and reside on the University campus in the manner ordinarily expected of a student.

               03.7. It is contended that, instead of adopting a compassionate, reasonable and inclusive approach having regard to the circumstances of the petitioner, the 1st respondent has treated the attendance shortfall as an absolute impediment to his academic progression and, by its decision dated 23.04.2026, has effectively compelled him to take an academic break. Learned counsel submits that the condition imposed by the 1st respondent that the petitioner should return only when he is capable of residing on the campus independently and without assistance fails to take into account the nature of the difficulties faced by the petitioner.

               03.8. It is further submitted that the impugned action has consequences extending beyond the immediate academic year, since the petitioner's continuation in the course is intrinsically connected with the continuation of the scholarship extended to him under the National Fellowship & Scholarship for Higher Education of Scheduled Tribe Students. It is therefore submitted that denial or interruption of the scholarship would cause serious prejudice to the petitioner and may effectively jeopardise his ability to complete the integrated law programme.

               03.9. It is further submitted that the 2nd respondent-Union of India, through the Ministry of Tribal Affairs, administers the aforesaid Scholarship Scheme for the benefit of eligible Scheduled Tribe students pursuing higher education, and that the 1st respondent-University is a notified institution under the said Scheme. The petitioner, being an eligible Scheduled Tribe student pursuing his course at the 1st respondent-University, has been receiving the benefit of the Scheme for pursuing his education.

               03.10. It is therefore submitted that the petitioner's case deserves to be considered not merely from the standpoint of the technical requirement of attendance, but also from the perspective of his overall academic record, his Scheduled Tribe status, his economic circumstances, the medical difficulties pleaded by him, his previous successful completion of two years of the course, and the serious consequences that would follow from discontinuation of his academic progression and scholarship. Hence, he prayed to set aside the decision of the 1st respondent dated 23.04.2026 and direct the respondents to promote the petitioner from fourth year (Semester VII) of the B.A., LL.B., (Hons.) programme for the academic year 2026-27 and permit him to attend the classes of the fourth year by online mode and permit him to clear his pending courses through the repeat/re-registration mechanism, and continue the petitioner’s scholarship under the National Fellowship & Scholarship for Higher Education of Scheduled Tribe Students for the academic year 2026-27.

04.1. On the other hand, the learned Standing Counsel for National Academy of Legal Studies and Research (NALSAR) University of Law, on written instructions, submitted that the petitioner is not entitled to the relief sought in the writ petition, as he admittedly failed to satisfy the minimum attendance requirements prescribed under the Academic Regulations of the University. It is submitted that the petitioner cannot seek to avoid the legal consequences flowing from his admitted shortage of attendance by invoking the extraordinary jurisdiction of this Court.

               04.2. Learned Standing Counsel further submitted that the respondent University has consistently maintained that its Attendance Regulations are valid, binding and enforceable and continued to operate throughout the relevant academic period. It is further submitted that, notwithstanding its consistent legal stand, the respondent University, after due deliberation and with a view to avoiding hardship to the students who had been detained solely on account of shortage of attendance, and to bring quietus to the disputes arising out of the ongoing litigation concerning attendance norms, has decided to extend, subject to the orders of this Court, a one-time exceptional measure to all students who were declared ineligible to appear for the examinations solely on account of shortage of attendance during the relevant academic period and were consequently detained.

               04.3. It is further emphasized that the said proposal has been made entirely without prejudice to the University's legal contention that its Attendance Regulations have remained valid, applicable and enforceable at all material times and that the factual foundation contemplated by the Hon'ble Supreme Court for granting equitable relief does not exist in the case of NALSAR University.

               04.4. It is further submitted that the proposed exemption is purely exceptional in nature and is intended only to resolve the present controversy. The same shall not constitute a precedent for future academic years, nor shall it be construed as an amendment, dilution or relaxation of the University's Academic Regulations governing attendance. It is also submitted that the proposed exemption shall not create any vested or recurring right in favour of any student to seek similar relief in future.

               04.5. It is further submitted that the scope of the one-time exemption is strictly limited to permitting the eligible detained students to appear for a special repeat examination, notwithstanding their shortage of attendance, together with consequential provisional promotion to the next academic year. Such provisional promotion, however, shall remain subject to the students successfully clearing the special repeat examination and fulfilling all other applicable academic requirements prescribed by the University.

               04.6. It is further submitted that the special repeat examination would be conducted at the earliest possible opportunity. The conduct of such examination and the grant of provisional promotion shall not be construed as amounting to any relaxation, modification or waiver of the University's Academic Regulations governing attendance or any other academic requirement. Likewise, the same shall not entitle any student to claim any further accommodation, concession, exemption or academic relaxation in future.

               04.7. It is further submitted that, insofar as attendance in classes, participation in academic instruction, residence on the University campus, or grant of any accommodation, concession or other academic relaxation is concerned, every student seeking such benefit on medical or other exceptional grounds shall continue to be governed by the recommendations of the duly constituted Medical Board and by the orders passed by the competent University authorities based on such recommendations.

                04.8. It is further submitted that the grant of the proposed one-time exemption shall not, by itself, confer any right upon any student to seek waiver of attendance requirements, residential accommodation, academic concessions or any consequential or ancillary relief. All such issues shall continue to be independently regulated in accordance with the applicable Academic Regulations, the recommendations of the Medical Board, and the decisions of the competent authorities of the respondent University. Accordingly, he requested that, while safeguarding the autonomy of the respondent University and without diluting the binding nature of its Attendance Regulations, appropriate orders may be passed by this Court in terms of the one-time exceptional proposal placed by the respondent University.

05. Having regard to the submissions made on either side and upon perusal of the record, it is appropriate to take note of the order dated 21.07.2026 passed by the Hon'ble Supreme Court in Prakruthi Jain v. Bar Council of India, W.P.(C) No.31 of 2025 and batch matters. The issue before the Hon'ble Supreme Court arose out of the uncertainty concerning mandatory attendance requirements in law colleges following the judgment of the Delhi High Court dated 03.11.2025 and the subsequent interim order of the Hon'ble Supreme Court dated 26.05.2026.

06. The Hon'ble Supreme Court noticed that, consequent upon the Delhi High Court judgment and the communication issued by the Bar Council of India, several students pursuing law courses had proceeded on the bona fide belief that shortage of attendance would not prevent them from appearing in the examinations for the ongoing academic session. The Hon'ble Supreme Court, therefore, held that such students were entitled to the benefit of doubt as a one-time measure only. The Hon'ble Supreme Court, accordingly, directed that students whose academic session was ongoing when the judgment of the Delhi High Court dated 03.11.2025 was rendered should not be detained or prevented from appearing in the final examinations for that academic session on account of shortage of attendance. It was further directed that students who could not appear in the final examination, either wholly or partially, should be permitted to take the supplementary examination for that academic session.

07. The principle emerging from the aforesaid order is that, where a student has been placed in an academic predicament on account of the peculiar uncertainty surrounding the attendance regime, the student should not, merely on account of such attendance shortfall, be made to suffer the irretrievable consequence of loss of an academic year. At the same time, the Hon'ble Supreme Court has expressly confined the benefit to a one-time measure, thereby preserving the regulatory authority of educational institutions in respect of future academic sessions.

08. In the present case, though arising from the individual circumstances of the petitioner, also has to be considered in the backdrop of the aforesaid pronouncement of the Hon'ble Supreme Court and the one-time exceptional measure voluntarily proposed by the respondent-University. The University itself has placed before this Court a proposal intended to avoid hardship to students detained solely on account of attendance shortage, while expressly reserving its right to enforce the Attendance Regulations in future. In the peculiar facts and circumstances of the case, this Court is of the view that the petitioner should not be compelled to lose the academic year merely on account of the attendance shortfall in question. Such a course would also be inconsistent with the spirit of the one-time protective measure adopted by the Hon'ble Supreme Court in the aforesaid proceedings and the corresponding exceptional measure proposed by the respondent-University.

09. In that view of the matter, as a one-time exceptional measure and without treating the same as a precedent for any future academic year, the period from the date on which the classes for the concerned academic semester commenced shall, for the limited purpose of the petitioner's present academic progression, be treated as attendance by the petitioner. This direction shall not be construed as a declaration that the petitioner's actual attendance satisfied the requirements under the University's Academic Regulations, nor shall it amount to a permanent waiver, dilution or relaxation of the Attendance Regulations. Consequently, the impugned decision dated 23.04.2026, insofar as it directs the petitioner to take a forced academic break on account of the attendance shortfall and thereby prevents him from pursuing the next stage of his academic programme, cannot be permitted to operate to the extent indicated above. The respondent-University shall accordingly permit the petitioner to pursue the fourth year (Semester VII) of the B.A., LL.B. (Hons.) programme for the academic year 2026-27, subject, however, to his satisfying the applicable academic requirements and clearing such pending courses/examinations as may be required under the Academic Regulations and the one-time mechanism proposed by the University.

10. Insofar as the petitioner's request to attend the classes of the fourth year through online mode is concerned, the petitioner is granted liberty to submit an appropriate application before the respondent-University and the concerned competent authorities seeking permission to attend the fourth-year classes through online mode, placing before them all relevant material and medical recommendations in support of his request. Upon receipt of such application, the respondent-University and the concerned competent authorities shall consider the same, in accordance with the applicable Rules, Regulations, the recommendations of the duly constituted Medical Board, and in accordance with law. The authorities shall also keep in view the peculiar circumstances of the petitioner and the fact that the present order is being passed as a one-time exceptional measure. As regards the petitioner's scholarship under the National Fellowship & Scholarship for Higher Education of Scheduled Tribe Students, the respondents shall consider the petitioner's entitlement and continuation of the scholarship for the academic year 2026-27 in accordance with the applicable Scholarship Scheme and the petitioner's academic status consequent upon this order. The mere fact that the petitioner was subjected to an attendance-related academic impediment shall not, by itself, be treated as a ground to defeat the benefit of the present one-time academic arrangement, subject to fulfilment of the other eligibility conditions under the Scheme. It is made clear that the benefit granted by this order is confined strictly to the peculiar facts of the present case and to the present academic controversy. Nothing contained herein shall be construed as a general waiver of the attendance requirements prescribed by the respondent-University or as conferring upon the petitioner, or any other student, a right to seek similar relaxation in any future academic year. It is further made clear that all other academic requirements, including examinations, repeat/re-registration requirements, passing of pending courses and other conditions prescribed under the applicable Academic Regulations, shall continue to operate, except to the limited extent specifically modified by this order.

11. With the above observations and directions, this Writ Petition is disposed of. There shall be no order as to costs.

As a sequel, miscellaneous applications, if any, pending shall stand closed.