Authority: High Court of Judicature at Madras (Bench of Chief Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan)

Order Date: 29.06.2026

Case Overview

  • Parties: Appellant – Syeeda Asma, W/o Abdul Rahman, residing at No.17, Mosque Street, Muthapudupet, IAF Avadi, Chennai. Respondents – 1) The Registrar, University of Madras; 2) The Director, Institute of Distance Education, University of Madras; 3) University Grants Commission (represented by its Secretary).
  • Nature of Proceeding: Intra‑court appeal (WA No.1591 of 2026) under Clause 15 of the Letters Patent, challenging the order dated 23.02.2026 passed by the learned Single Judge in W.P. No.40698 of 2025.
  • Background:
  • The appellant completed B.Sc. (Psychology) from Tamil Nadu Open University (July 2020 – June 2024).
  • She applied for M.Sc. Psychology (distance education) at University of Madras for the academic year 2025 and received provisional admission on 02.07.2025.
  • On 30.09.2025, the University informed her that the University Grants Commission had imposed a total prohibition on conducting postgraduate psychology courses via distance mode, citing the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021, which classifies Psychology as a professional course unsuitable for correspondence.
  • The UGC’s decision was formally communicated on 12.08.2025, but the Distance Education Bureau had already taken a decision on 22.04.2025, prior to the appellant’s admission.
  • All other candidates switched to permissible courses; the appellant persisted and sought certiorari and mandamus to invalidate the regulatory notification.
  • Single Judge’s Order (23.02.2026): Declined to quash the UGC notifications; however, directed that the appellant be accommodated in a regular (non‑distance) M.Sc. Psychology seat in the next academic year, without reference to merit rank.
  • Counsel Submissions:
  • For the appellant (Mr. S. Mohammed Imran): argued that the admission was granted before the public notification, creating a vested right; contended that the ban should operate prospectively, not retrospectively.
  • For the respondents: emphasized that the NCAHP Act recognises Psychology as a healthcare profession requiring intensive clinical training; highlighted that the policy decision pre‑dated the admission; noted impracticality of running an entire programme for a single student.

Final Outcome

  • The Madras High Court dismissed the appeal, holding that the learned Single Judge’s equitable relief was appropriate and that no exemption could be carved out for a single candidate against a nationwide statutory prohibition.
  • The court reiterated the principle that private expectations cannot override a clear statutory policy formulated in the larger public interest.
  • Consequently, the order dated 23.02.2026 stands, and the appellant must seek admission in a regular (on‑campus) M.Sc. Psychology programme in the subsequent academic year, subject to merit‑based allocation.

Topics: Education Policy, Judicial Review