The Indian Institute of Management Ahmedabad approached the Gujarat High Court by filing an appeal against an order passed by a single judge that had set aside the institute’s decision to expel three students from its Doctoral Programme in Management. The expulsion had been ordered on the ground that the students failed to meet the requirements for promotion within the programme, but the single judge held that the action was not in conformity with the procedure laid down in the programme manual. The institute challenged this finding before a division bench of the High Court, asserting that the expulsion was in accordance with the governing rules of the programme.
The students concerned were enrolled in the Doctoral Programme in Management and were undergoing the coursework stage of the programme. A decision was taken by the institute stating that they had not satisfied the necessary academic requirements for promotion from the first year to the second year of the coursework stage. As a consequence, their candidature was withdrawn and they were directed to leave the programme. Aggrieved by this action, the students had approached the High Court, contending that the programme manual did not permit the institute to expel them at that stage of the programme. The single judge accepted this contention and quashed the expulsion order, prompting the institute to file an appeal.
The appeal was heard by a division bench comprising the Chief Justice and another judge. During the hearing, the bench closely examined the structure of the Doctoral Programme in Management and the provisions of the programme manual relied upon by the institute. The court sought clarity on whether the manual empowered the institute to require students to leave the programme during the first year of the coursework stage, particularly when that stage was prescribed to span a period of two years.
On behalf of the institute, counsel referred to a clause in the programme manual which stated that a student who had failed to qualify for promotion from one stage of the programme to the subsequent stage, or who had failed to complete the programme within the stipulated time, would be required to leave the programme. The counsel explained that the Doctoral Programme in Management was structured as a four-year programme, with a maximum permissible extension up to six years. The programme was divided into three distinct stages. The first stage consisted of coursework, the second stage involved the area comprehensive examination, and the third stage related to thesis work and assistance, including the identification and development of a research topic.
It was explained that the first stage, namely the coursework stage, was designed to be completed over two years and was divided into six terms. The programme began with an orientation and induction module, followed by various coursework components. According to the institute, the coursework stage was foundational and preparatory, enabling students to acquire the necessary academic grounding before progressing to the subsequent stages of the programme. The institute maintained that performance during this stage was critical and that students who failed to meet the required standards could not be allowed to continue indefinitely.
The court questioned the counsel as to whether the students had been expelled during the first stage itself, and it was confirmed that the expulsion occurred while the students were still in the coursework stage. The bench then observed that since the coursework stage was explicitly prescribed to last for two years, the concept of promotion from one stage to another would arise only after the completion of that stage. The court noted that the clause relied upon by the institute referred to failure to qualify for promotion from one stage to the next, such as from the coursework stage to the area comprehensive examination stage, and not to progression from one year to another within the same stage.
The bench pointed out that the students in question had not yet completed the two-year coursework stage and, therefore, had not reached the point at which their eligibility for promotion to the next stage could be assessed. On this basis, the court expressed doubt as to whether the clause cited by the institute could be invoked to justify their expulsion at that juncture. The judges remarked that a plain reading of the clause suggested that it was intended to apply only after the completion of a stage, not midway through it.
The court also referred to another provision of the programme manual which stated that a student declared not qualified for promotion at any stage of the programme, or not eligible for the award of the doctoral title, would be required to leave the programme unless otherwise recommended by the programme’s executive committee. The bench questioned how a student’s qualification for promotion at a particular stage could be determined before the completion of the full duration prescribed for that stage. It asked the institute to identify a specific provision in the manual that permitted the expulsion of students during the first year of the two-year coursework stage.
In response, counsel for the institute sought to rely on the overall design and intent of the programme as reflected in various clauses of the manual. It was argued that the coursework stage, although spread over two years, involved continuous assessment and evaluation, and that the institute retained the authority to assess whether a student was capable of meeting the programme’s academic standards. However, the court reiterated that the language of the relevant clause did not contemplate promotion from the first year to the second year within the same stage, but rather referred to promotion from one stage of the programme to the next.
The bench emphasized that academic rules, programme manuals, and regulations framed by educational institutions must be followed strictly and interpreted with the same rigor as statutory provisions. According to the court, when an institute frames a detailed manual governing the rights and obligations of students, it is bound by the language of that manual and cannot act beyond its terms. The judges observed that, on a reading of the manual placed before them, there did not appear to be any provision that expressly authorized the institute to expel students solely on the basis of their performance during the first year of the coursework stage.
When counsel for the institute argued that the programme manual should not be interpreted in the same manner as a statute, the court disagreed. The bench stated that for any academic programme, especially one involving serious consequences such as expulsion, the governing rules and manuals must be construed with precision and certainty. The court noted that students organize their academic lives based on the rules communicated to them, and any adverse action must strictly conform to those rules.
The institute’s counsel further contended that if the interpretation adopted by the single judge were accepted, it would lead to an anomalous situation where even a student who failed in all components of the coursework could continue in the programme for an extended period. According to the institute, such an interpretation would undermine academic standards and the integrity of the programme. The counsel sought to demonstrate, by referring to various provisions, how the term “stage” was used in the manual and how the institute understood its authority to evaluate and discontinue students who failed to meet academic benchmarks.
The court heard these submissions and indicated that it would examine the provisions in greater detail. After hearing arguments for some time, the bench decided to list the appeal for further hearing, indicating that the issues raised required closer scrutiny. The court did not pass any final order at that stage but made observations that reflected its preliminary concerns regarding the interpretation of the programme manual and the timing of the expulsion.
The appeal was filed by the Indian Institute of Management Ahmedabad along with other connected appellants against the students who had challenged their expulsion. The matter was registered as a regular appeal before the Gujarat High Court. The outcome of the case would determine whether the institute’s interpretation of its programme manual and its authority to expel students during the coursework stage would be upheld or whether the single judge’s view would prevail.
The proceedings highlighted the tension between institutional autonomy in academic matters and the requirement to adhere strictly to prescribed rules and procedures. The High Court’s examination focused on the precise wording of the programme manual and the stage at which students could be lawfully required to leave the programme. The case continued to remain pending for further consideration by the division bench.
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