Rajasthan High Court Quashes PhD Merit List Over UGC Eligibility Violations
The Rajasthan High Court has set aside the University of Rajasthan's PhD admission merit list insofar as it affected a petitioner's candidature, holding that universities cannot exercise academic autonomy in disregard of binding regulatory requirements prescribed by the University Grants Commission (UGC).
Justice Sameer Jain delivered the judgment on October 30, 2026, while deciding writ petitions challenging the university's PhD admission process for the 2025–2026 academic session. The dispute concerned the evaluation of candidates belonging to different UGC-NET qualification categories.
Background of the Case
The petitioner, Yash Chandra, a Scheduled Tribe (ST) candidate who had qualified for the UGC-NET Junior Research Fellowship (JRF) in Economics, challenged the first merit list issued by the University of Rajasthan on August 10, 2026.
He alleged that the university had clubbed three distinct categories of NET-qualified candidates into a common merit list and assessed all candidates exclusively on the basis of interview marks. According to the petitioner, this approach disregarded the separate evaluation methodologies prescribed under the UGC's public notice dated March 27, 2024.
The petitioner had applied for admission to the university's PhD programme in Economics under the JRF category. However, his candidature was rejected on the ground that he had not secured the prescribed qualifying marks in the interview. He subsequently submitted a representation to the Vice-Chancellor on August 11, 2026, before approaching the High Court.
Different Evaluation Criteria Under UGC Guidelines
The UGC public notice dated March 27, 2024, recognises three categories of NET-qualified candidates for PhD admissions:
- Category 1: Candidates qualified for JRF and eligible for appointment as Assistant Professors and PhD admission.
- Category 2: Candidates eligible for appointment as Assistant Professors and PhD admission, but not for JRF.
- Category 3: Candidates eligible for PhD admission only.
Under the prescribed framework, JRF-qualified candidates are considered for PhD admission based on their interview performance. Candidates belonging to Categories 2 and 3, however, are evaluated through a combined assessment carrying 70% weightage for NET scores and 30% for the interview.
The petitioner contended that applying identical interview-based evaluation to all three categories defeated the distinction expressly recognised by the UGC.
University Defends Its Admission Process
The University of Rajasthan defended its selection procedure, arguing that the merit list had been prepared in accordance with the applicable university admission rules and Ordinance 124. It further maintained that no separate seat quotas had been prescribed for the three categories of candidates.
The university also relied on the petitioner's participation in the interview to oppose his subsequent challenge to the selection process.
High Court: University Autonomy Is Not Absolute
Rejecting the university's justification, the High Court observed that academic autonomy does not provide universities with unrestricted authority to disregard statutory provisions or binding regulatory requirements.
The Court emphasised that the UGC's classification of NET-qualified candidates into three distinct categories was not merely descriptive or incidental. The corresponding evaluation methodologies were required to be given effect to while conducting PhD admissions.
It further clarified that the absence of separate category-wise seat quotas does not justify applying identical evaluation criteria to candidates belonging to different eligibility categories. Seat allocation and determination of merit are separate aspects of the admission process.
Referring to the Supreme Court's decision in Annamalai University v. Secretary to Government, Information and Tourism Department, (2009) 4 SCC 590, the High Court reiterated that institutional autonomy cannot be exercised in derogation of binding regulatory requirements.
Participation in Selection Does Not Validate an Unlawful Procedure
The Court also rejected the argument that the petitioner was barred from challenging the selection process merely because he had participated in the interview.
It observed that participation in a selection process does not confer authority upon a university to disregard mandatory legal requirements. Nor does such participation automatically validate an otherwise unlawful procedure.
The Court distinguished between claiming an automatic right to admission and claiming the right to have one's candidature considered in accordance with the legally prescribed eligibility and evaluation criteria.
While qualifying the UGC-NET-JRF examination does not automatically guarantee PhD admission, candidates are entitled to fair consideration under the applicable regulatory framework.
Final Decision and Directions
Allowing the writ petitions, the Rajasthan High Court held that the impugned merit list dated August 10, 2026, could not be sustained insofar as it affected the petitioner's candidature if the prescribed category-specific evaluation methodology had not been followed.
Accordingly, the Court:
- Quashed and set aside the impugned merit list insofar as it affected the petitioner's candidature.
- Directed the university to reconsider his application for admission to the PhD programme in Economics under the JRF category.
- Required the university to apply the relevant UGC Regulations, the public notice dated March 27, 2024, and the Rajasthan University PhD Admission Scheme (RUPA) 2025, read with the applicable corrigendum.
- Directed the university to ensure that the evaluation methodology was consistent with the regulatory framework governing the petitioner's category.
Legal Significance
The judgment reinforces the principle that university autonomy must operate within the boundaries of statutory and regulatory compliance. Although courts generally exercise restraint in academic matters, such restraint does not prevent judicial review where an institution is alleged to have acted contrary to binding legal requirements.
The decision also highlights the importance of transparent and legally compliant admission procedures, particularly where different eligibility categories are governed by distinct evaluation standards.
Case: Yash Chandra v. State of Rajasthan & Others
Citation: 2026:RJ-JP:42065
Court: Rajasthan High Court, Jaipur Bench
Judge: Justice Sameer Jain
Decision Date: October 30, 2026
Source: Rajasthan High Court Judgment; Indian Express, November 3, 2026.