In a landmark judgment, the Andhra Pradesh High Court addressed the issue of strict attendance requirements in educational institutions, particularly when students face genuine medical emergencies. The case involved a B.Tech student from GMR Institute of Technology whose third-semester results were withheld, and he was barred from attending fourth-semester classes due to insufficient attendance. The student had missed classes during two separate periods owing to acute illnesses, including gastroenteritis and typhoid fever, substantiated by medical certificates from a government health center.
The institution's Academic Regulation No. 9(b) stipulated that attendance could only be condoned up to 10% for medical reasons, requiring a minimum of 65% attendance. The student’s attendance fell below this threshold, prompting the college to enforce the regulation strictly. However, the student contested this decision, arguing that his medical conditions were unforeseen and beyond his control.
Justice Gannamaneni Ramakrishna Prasad, presiding over the case, critically examined the regulation's rigidity. He emphasized that illnesses are inherently unpredictable and beyond human control, making it unreasonable to impose a fixed limit on attendance condonation for medical reasons. The judge noted that the regulation, formulated by a private institution, lacked the flexibility to accommodate genuine health-related absences, rendering it arbitrary and irrational.
The court highlighted that while maintaining academic standards is essential, regulations must also consider individual circumstances, especially when supported by credible medical evidence. It was observed that the regulation failed to align with Article 14 of the Indian Constitution, which guarantees equality before the law, as it did not allow for discretion in cases of genuine medical emergencies.
Consequently, the High Court directed GMR Institute of Technology to release the student's third-semester results and permit him to continue with his fourth-semester studies. This decision underscores the judiciary's role in ensuring that educational regulations are applied fairly and do not unjustly penalize students facing legitimate hardships.
This ruling sets a precedent for educational institutions to adopt a more compassionate approach when dealing with attendance shortfalls due to medical reasons. It calls for a balance between upholding academic integrity and recognizing the unpredictable nature of health issues, ensuring that students are not unduly disadvantaged by inflexible policies.
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