Court Dismisses Petition of Candidate Seeking PhD Interview Based on 2009 JEST Score, Affirms Binding Nature of UGC Regulations 2022 and Recent UGC Public Notice
In a significant judgment dated October 1, 2026, the Allahabad High Court (Lucknow Bench) clarified the eligibility criteria for PhD admissions in Indian universities, emphasizing strict adherence to University Grants Commission (UGC) norms. The court dismissed the writ petition filed by Mr. Aakash Narayan, who sought a direction to Dr. Shakuntala Misra National Rehabilitation University, Lucknow, to consider his application for a PhD program interview based on his Joint Entrance Screening Test (JEST) score from 2009, instead of the University Grants Commission National Eligibility Test (UGC NET) score mandated by the university.
Mr. Narayan, having completed his MSc in Astronomy from Osmania University, contended that his JEST qualification-a national-level examination recognized by certain research institutes-should be deemed equivalent to the UGC NET score, which the university had adopted as the sole eligibility criterion pursuant to the UGC (Minimum Standards and Procedure for Award of Ph.D. Degree) Regulations, 2022. He argued that the respondent university's refusal to call him for the interview was arbitrary and requested compensation for the alleged career prejudice caused.
The university, represented by Advocate Atul Kumar Dwivedi, countered that it had formally adopted the UGC NET score requirement for PhD admissions as per a resolution dated October 26, 2024, and publicly notified this criterion in its academic prospectus for the 2025-26 session. It submitted that the UGC Regulations of 2022, which are binding on all higher education institutions, mandated the use of NET scores as eligibility for PhD admissions, reinforced by a UGC public notice dated March 27, 2024. The university also noted that JEST scores were not recognized equivalently by it or the UGC as a substitute for the NET score.
The Court meticulously examined the relevant UGC regulations and the university's published admission guidelines. It acknowledged that while JEST is recognized by certain participating institutes and the Anusandhan National Research Foundation (ANRF) as a national eligibility test, this recognition does not universally compel all universities to accept JEST scores for PhD admissions. The Court highlighted that the UGC's 2022 Regulations and the 2024 public notice explicitly endorsed NET scores as the standardized eligibility criterion to unify and simplify the admission process under the National Education Policy 2020 framework.
Importantly, the Court noted that the petitioner's JEST score dated back to 2009, with no evidence provided regarding its validity or relevance for the 2025-26 academic year. Consequently, the Court found no basis to treat the old JEST score as a valid qualification for admission in the current academic cycle. The petitioner's failure to produce any NET score or valid equivalent meant that the university's refusal to call him for interview was lawful and consistent with binding regulations.
The Court further observed that the petitioner's application had been submitted with full knowledge of the university's eligibility criteria, and that these criteria were clearly published and non-arbitrary. Therefore, it rejected the petitioner's claim for compensation or any other relief.
In conclusion, the Allahabad High Court upheld the primacy of UGC's regulatory framework for PhD admissions, confirmed the binding nature of UGC NET as the eligibility test, and clarified that JEST scores, while nationally recognized by some bodies, are not universally accepted and cannot be enforced as equivalent by universities unless specifically adopted. The petition was dismissed with no order as to costs.
This judgment reinforces the need for candidates to comply with the exact eligibility requirements prescribed by universities and approved by statutory authorities, ensuring uniformity and fairness in higher education admissions.
Bottom Line:
Education - Ph.D. admission - University adopting UGC NET score as eligibility criterion in terms of UGC Regulations, 2022 and UGC public notice - Candidate possessing only JEST score cannot compel university to treat JEST as equivalent to NET or call him for interview - Old JEST score of 2009, without proof of validity, cannot found a claim for admission or compensation.
Statutory provision(s):
Article 226, Constitution of India, University Grants Commission (Minimum Standards and Procedure for Award of Ph.D. Degree) Regulations, 2022, UGC Public Notice dated 27.03.2024
