The court ruled against the unilateral alteration of statutory body's recommendations by the Registrar, emphasizing adherence to procedural fairness.
In a landmark judgment, the Patna High Court has quashed the decision of the Registrar of Patliputra University to unilaterally alter the recommendation for permanent affiliation granted to Catalyst College and Catalyst Institute of Management and Advance Global Excellence. The judgment, delivered by Justice Alok Kumar Sinha, emphasized that the Registrar's action was beyond its authority and violated principles of natural justice.
Catalyst College, represented by senior advocate Mrigank Mauli, had sought relief from the court after the Registrar issued a corrigendum on June 24, 2025, changing the status from permanent to temporary affiliation and reducing intake seats for the BCA course from 240 to 120. The court noted that the statutory bodies of the university, including the Affiliation and New Teaching Programme Committee (ANTPC), Academic Council, Syndicate, and Senate, had unanimously recommended permanent affiliation and seat enhancement.
Justice Sinha highlighted that the Registrar's actions were inconsistent with the statutory framework under the Bihar State Universities Act, 1976, as they did not follow due process, nor did they provide reasons or an opportunity for the college to be heard. The judgment underscored that administrative authorities cannot override decisions made by statutory bodies without explicit legal authority.
Furthermore, the court addressed the issue of the All India Council for Technical Education's (AICTE) annual Extension of Approval, stating that it does not impede the grant of permanent affiliation under the Bihar State Universities Act. However, the court clarified that while permanent affiliation may be granted, the institution must comply with AICTE's regulatory framework regarding course conduct and student intake.
Consequently, the court restored the recommendation for permanent affiliation and directed the state authorities to process it in accordance with law, ensuring that the affiliation operates within AICTE's regulatory limits.
The judgment is seen as a significant reinforcement of procedural fairness and statutory compliance, setting a precedent for university administrative actions across the state.
Bottom line:-
University Registrar's unilateral alteration of statutory body's recommendation for permanent affiliation without adhering to procedural fairness is contrary to law.
Statutory provision(s): Bihar State Universities Act, 1976 Section 21(2)(d), AICTE Regulations, Principles of Natural Justice, Articles 14 and 19(1)(g) of the Constitution of India
Catalyst College v. State of Bihar, (Patna) : Law Finder Doc id # 2940080
