![University's Own Lapse Cannot Block Degree Verification, Student Not to Be Sent to Civil Court: Supreme Court in Mohd. Asad Choudhary v. State of Himachal Pradesh [2026 INSC 1127]](/assets/images/article-criminal.svg)
Quick Answer: A bona fide student cannot be denied verification of his degree because the University itself failed to include his name in the admission disclosure list. Where only a discrepancy in semester marks remains, and the result is "pass" on either set of figures, the student should not be sent to a civil court; the Supreme Court directed the University to issue corrected marks certificates and send the verification report to his employer within three weeks.
In Mohd. Asad Choudhary v. State of Himachal Pradesh & Ors. (2026 INSC 1127), the Supreme Court set aside, qua the appellant, the Himachal Pradesh High Court's order dated 20.12.2024 relegating students of Manav Bharti University to the competent court, holding that he was a bona fide student and that the University's own lapse could not be visited on him (paras 16, 19). It directed the University to issue corrected 7th and 8th semester marks certificates and forward the verification report to his employer within three weeks, and expected the employer to release his salary arrears within a further four weeks (paras 20–21).
Status: Appeal allowed; High Court order set aside qua the appellant; time-bound directions for verification and release of salary arrears (paras 19–22).
Headnote: University's Lapse Cannot Block Verification of Degree
Education – Private university – Degree verification – Name omitted from admission disclosure list – Clerical error admitted by University – Mismatch in semester marks – Result "pass" on either set – Relegation to civil court unwarranted – Directions for corrected marks certificates and verification – Release of salary arrears.
Held: (i) The University admitted that the appellant was admitted against an allotted seat, cleared all eight semesters, was issued all marks certificates and is reflected in the Green Sheet Register (paras 11, 14).
(ii) The University's explanation that his data could not be sent because of the marks mismatch cannot be reconciled with its admission of a clerical error, since the disclosure list pertains to 2014-15 and the mismatch to examinations of 2017–18; the clerical-error explanation was accepted (para 15).
(iii) The appellant was a bona fide student, and the University's lapse cannot be visited with adverse consequences on him or justify withholding verification (para 16).
(iv) On either set of marks for the 7th and 8th semesters, the result is "pass"; the discrepancy does not touch his admission, status or passing of the course (para 17).
(v) The only surviving issue is a verification of the University's own result records, which does not warrant relegating him to a court of competent jurisdiction (paras 18–19).
(paras 2–22)
Case Details: Mohd. Asad Choudhary v. State of Himachal Pradesh (2026 INSC 1127)
Final Outcome: Appeal allowed; High Court order dated 20.12.2024 set aside qua the appellant; directions for corrected marks certificates, verification report within three weeks and release of salary arrears within a further four weeks; no costs.
Case: Mohd. Asad Choudhary v. State of Himachal Pradesh & Ors.
Neutral Citation: 2026 INSC 1127
Case No.: Civil Appeal No. ___ of 2026 (arising out of SLP (C) No. 474 of 2026)
Court: Supreme Court of India (Civil Appellate Jurisdiction) – Non-Reportable
Date of Decision: 14 October 2026
Bench: Justice Vikram Nath, Justice Augustine George Masih and Justice Sandeep Mehta (authored by Justice Augustine George Masih)
Relevant Acts & Sections: Constitution of India – Article 226 (writ petition); verification of academic credentials through the Document Verification Committee constituted by Notification dated 16.08.2022
Impugned Order: Judgment and order dated 20.12.2024 of the High Court of Himachal Pradesh at Shimla in CWP No. 14955 of 2024, decided along with CWPIL No. 22 of 2022 and connected petitions (paras 2, 8).
Source: Supreme Court of India (official website)
Key Holdings of the Supreme Court
- A University's admission of a clerical error in omitting a student's name from the disclosure list binds it, and the omission cannot be held against the student (paras 14–16).
- An explanation in a counter affidavit that contradicts the University's own earlier statement and records will not be accepted (para 15).
- A marks discrepancy that leaves the result "pass" either way does not affect admission, student status or the degree (para 17).
- Where only verification of the University's own records remains, relegating the student to a civil court is unwarranted (paras 18–19).
- The employer is expected to release salary arrears with consequential benefits once verification is received (para 21).
Brief Facts of the Case
The appellant studied B.Tech (Civil Engineering) at Manav Bharti University in the 2014–2018 session and received his degree dated 15.10.2018 in the first division. He was appointed Sub-Inspector in the State Taxes Department, Jammu and Kashmir, and his employer sought verification of his degree from 2022 onwards, making his appointment subject to it (paras 3–4).
After cases were registered over alleged sale of degrees by the University, its records were seized by the Special Investigation Team. The High Court took up CWPIL No. 22 of 2022 with individual writ petitions, and a Document Verification Committee chaired by the Superintendent of Police, Solan was constituted (paras 5–6).
The Committee found his name in the Green Register but not in the admission disclosure list, and a mismatch between the result gazette and the Green Sheet for the 7th and 8th semesters. The High Court disposed of the matters on 20.12.2024, leaving students to approach the competent court (paras 8, 10).
In the Supreme Court, the University admitted his admission, results and Green Sheet entry, attributing the omission from the disclosure list to a clerical error. The Committee confirmed his enrolment in an additional affidavit (paras 11–14).
Issues Before the Supreme Court
- Whether the omission of the appellant's name from the admission disclosure list could justify withholding verification of his credentials (paras 14–16).
- Whether the marks discrepancy required the appellant to be relegated to a civil court (paras 17–19).
Court's Findings and Reasoning
University's admissions (para 14): The University admitted his admission against an allotted seat, his passing of all eight semesters, issue of all marks certificates and his entry in the Green Sheet Register.
Contradictory explanation rejected (para 15): The claim that his data could not be sent due to the marks mismatch could not be reconciled with the disclosure list relating to 2014-15 while the mismatch related to December 2017 and May 2018 examinations. The clerical-error explanation, which accorded with the letter dated 26.07.2024, was accepted.
Bona fide student (para 16): The appellant had no role in the University's lapse, which could not be visited with adverse consequences on him.
Marks discrepancy immaterial to passing (para 17): On either set of figures the result was "pass", and no respondent suggested otherwise.
Only verification remains (paras 18–19): Which set of marks is correct is a matter of verifying the University's own records, not of evidence, so relegation to a civil court was not warranted.
Final Outcome and Directions
- High Court order dated 20.12.2024 set aside qua the appellant (para 19).
- The State to provide the 7th and 8th semester result records available with the Committee to the University (para 20).
- The University to issue corrected Detailed Marks Certificates of the 7th and 8th semesters and forward the verification report to the Additional Commissioner, State Taxes (Administration and Enforcement), Kashmir within three weeks (para 20).
- The employer is expected to release all salary arrears with consequential benefits within a further four weeks of receiving verification (para 21).
- Appeal allowed; no order as to costs (paras 22–23).
Legal Principle Laid Down
A lapse admitted by a University in its own records cannot be used to deny a bona fide student verification of his academic credentials, and where only verification of the University's own records remains, the student should not be relegated to a civil court (paras 16, 18–19).
Precedents Relied Upon
- No precedent is cited in the judgment.
Important Paragraphs of the Judgment
Verbatim extracts from the judgment. For the full text, refer to the judgment PDF below.
Para 16: "The affidavits and the documents on record thus leave no manner of doubt that the Appellant was a bona fide student at the University, admitted against an allotted seat, who appeared in and cleared all his examinations."
Para 16: "Such a lapse cannot be visited with adverse consequences upon the Appellant, nor can it be a ground for withholding the verification of his academic credentials."
Para 17: "None of the respondents has suggested otherwise."
Para 17: "Therefore, it stands established that the Appellant has validly passed all the examinations, as indeed the entire course and was duly conferred with the degree as per his entitlement."
Para 18: "That issue calls for no more than a verification of the result records of the University, which does not depend upon any evidence that the Appellant could lead, nor require the Committee to create or alter any record, being in the nature of the responsibility of verification entrusted to the Committee."
Para 19: "Therefore, the impugned order dated 20.12.2024 passed by the High Court is set aside qua the Appellant."
Practical Impact of the Ruling
- For students: A University's own record-keeping lapse cannot be held against a student who was validly admitted and passed (para 16).
- For universities and verification committees: Verification of their own records must be completed, not deferred to civil litigation (paras 18, 20).
- For government employers: Salary withheld pending verification is expected to be released with consequential benefits once verification arrives (para 21).
FAQs on Degree Verification and University Lapses
1. What did the Supreme Court decide in Mohd. Asad Choudhary v. State of Himachal Pradesh?
It set aside the High Court's order qua the appellant and directed time-bound verification of his degree and release of his salary arrears (paras 19–21).
2. Why was the omission from the admission disclosure list not held against him?
The University admitted it was a clerical error by its previous administration, and he had no role in it (paras 14–16).
3. Did the mismatch in 7th and 8th semester marks matter?
No. On either set of figures his result was "pass", so it did not affect his admission, status or degree (para 17).
4. Why was he not sent to a civil court?
Only verification of the University's own result records remained, which needed no evidence from him (paras 18–19).
5. What are the time limits set by the Court?
Three weeks for the University to issue corrected certificates and send the verification report, and a further four weeks for the employer to release salary arrears (paras 20–21).
Keywords: 2026 INSC 1127, Mohd. Asad Choudhary v. State of Himachal Pradesh, Manav Bharti University, degree verification, admission disclosure list, HP-PERC, Green Sheet Register, Detailed Marks Certificates, salary arrears, Supreme Court non-reportable judgment
Related on LegalTaxGuru
Download Judgment PDF – Mohd. Asad Choudhary v. State of Himachal Pradesh
Source: Supreme Court of India (official website).