The Madhya Pradesh High Court held that marriage and pregnancy cannot be treated as obstacles to a woman’s right to pursue and complete her education, and directed an educational institution to grant attendance relaxation and necessary academic support to a student who had missed classes due to maternity. The Court emphasised that educational institutions are duty-bound to accommodate female students during pregnancy and motherhood, in the same spirit in which maternity protections are recognised in employment, so that women are not forced to abandon their studies because of personal life circumstances.
The case concerned a female student enrolled in a Bachelor of Unani Medicine and Surgery course at a government autonomous Unani medical college. After successfully completing her first year, the student married during her second year of study and subsequently became pregnant. Owing to pregnancy-related health issues and childbirth, she was unable to attend classes regularly and her attendance fell below the minimum percentage prescribed under the college regulations for eligibility to appear in semester examinations. Although the institution granted her a limited relaxation of attendance, it was insufficient to meet the mandatory requirement, and she was consequently barred from sitting for her examinations.
Aggrieved by this decision, the student approached the High Court, contending that denial of permission to appear in examinations solely on account of pregnancy-related absence amounted to discrimination and violated her right to education. She sought maternity leave, further relaxation of attendance norms, and a direction to allow her to continue her course without academic penalty. During the pendency of the proceedings, the High Court passed an interim order permitting her to appear in the examination, though the declaration of her results was kept in abeyance.
In examining the matter, the High Court noted that regulatory bodies had issued directions requiring educational institutions to frame policies for maternity and child care leave for female students. The Court observed that despite such directives, the college had failed to formulate any comprehensive maternity policy for students and instead relied strictly on attendance rules without considering the exceptional circumstances of pregnancy and childbirth. The Court found that such an approach defeated the very purpose of extending maternity protections and undermined women’s educational rights.
The High Court held that the principles underlying maternity benefits in employment law are equally relevant in the academic context. It observed that just as women in the workforce are entitled to maternity leave and related protections to ensure continuity of employment, female students must also be afforded reasonable accommodations to ensure continuity of education. The Court stressed that pregnancy is a natural biological condition and cannot be a ground to penalise women or force them to discontinue their studies. Denying attendance relaxation in such circumstances, the Court noted, would have the effect of discouraging women from pursuing higher education after marriage or motherhood.
The Bench further observed that attendance requirements, though important for maintaining academic standards, cannot be applied mechanically without considering human realities and constitutional values of equality and non-discrimination. It held that institutions must adopt a flexible and humane approach in cases involving maternity, and should, where necessary, provide additional support such as extra classes, access to study materials, or other academic assistance to enable the student to meet minimum academic requirements.
Taking note of the specific facts of the case, the High Court treated the matter as a special case warranting relaxation. It directed the college to grant attendance relaxation to the extent required to make the student eligible to appear in her examinations and to extend all necessary academic facilities to ensure that she could complete her course. The Court clarified that marriage or pregnancy during the course of studies cannot be viewed as disqualifying factors and must not be allowed to derail a woman’s educational journey.
The judgment underscored that education is a fundamental tool for empowerment and that women must not be compelled to choose between motherhood and education. By directing institutions to accommodate maternity-related needs of students, the High Court reaffirmed the principle that academic rules should be interpreted in a manner consistent with constitutional guarantees of equality, dignity, and the right to education.
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