In a significant ruling, the Kerala High Court held that denying an individual’s rights due to an inability to perform an impossible task is a violation of Article 14 of the Indian Constitution. This judgment reinforces the principle of the "Doctrine of Impossibility," emphasizing that legal obligations cannot be imposed on individuals if fulfilling them is inherently impossible.
Case Background: The case arose from the petitioners, who were denied an equivalency certificate by the Kerala Agricultural University (KAU). The petitioners had completed their Bachelor of Science (Honors) in Agriculture from a university in Coimbatore during 2017-18, graduating in 2021. KAU rejected their request for an equivalency certificate to apply for Public Service Commission (PSC) exams because their university lacked accreditation from the Indian Council of Agricultural Research (ICAR) during their period of study.
The Petitioners' Argument: The petitioners contended that they were the first batch of students from their university. According to ICAR guidelines, accreditation can only be granted to higher educational institutions after at least one batch of students has graduated. Hence, their university could only apply for ICAR accreditation after they completed their course. The petitioners argued that it was practically impossible for them to obtain the equivalency certificate due to this requirement, which was beyond their control.
Court’s Reasoning: Justice Ziyad Rahman A.A. relied on the "Doctrine of Impossibility" to support his judgment. The doctrine, rooted in the legal maxim "lex non cogit ad impossibilia" (the law does not compel a man to do what he cannot possibly perform), suggests that the law should not demand the impossible. In this context, the court noted that the petitioners could not be compelled to fulfill an impossible requirement, and denying them the equivalency certificate would be unjust.
Legal Precedents: The court referenced the Supreme Court’s decision in the case of Indore Development Authority vs. Manoharlal and Others (2020). The Supreme Court had observed that if an order of the court disables a person from taking any action, the doctrine "nemo tenetur ad impossibilia" (no one is bound to do the impossible) would apply. This precedent was crucial in reinforcing the Kerala High Court's application of the Doctrine of Impossibility in the current case.
Violation of Article 14: The court emphasized that denying the petitioners an equivalency certificate due to an impossibility would violate Article 14 of the Constitution, which guarantees equality before the law. The court stated that the petitioners, being the first batch of students, were unfairly discriminated against by a requirement they could not meet through no fault of their own. This amounted to unreasonable classification, which is prohibited under Article 14.
Directive to Kerala Agricultural University: The court directed KAU to provide the petitioners with the equivalency certificates, considering the exemption granted by ICAR to the first batch of students. The court highlighted that ICAR itself had recognized the unique situation of the first batch of students and had exempted them from the accreditation requirement to pursue further studies.
Implications of the Ruling: This ruling has far-reaching implications for educational institutions and regulatory bodies. It underscores the need for flexibility and fairness in applying regulatory requirements, especially when compliance is impossible due to circumstances beyond the control of individuals or institutions. The judgment also reinforces the importance of Article 14 in ensuring that no individual or group is unfairly discriminated against by the law.
Conclusion: The Kerala High Court's decision is a landmark in the application of the Doctrine of Impossibility in Indian jurisprudence. By upholding the principle that the law should not compel the impossible and ensuring that individuals are not unfairly discriminated against, the court has reinforced the protection of fundamental rights under Article 14. This judgment will likely influence future cases where individuals or institutions face impossible legal obligations, promoting fairness and justice in the legal system.
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