Karnataka HC Quashes KSLU Circular Forcing Repeater Students to Sit Exams in Subjects Never Taught to Them

The Karnataka High Court struck down a Karnataka State Law University circular that required repeater LLB students to appear for revised syllabus subjects their college had never taught, holding the direction arbitrary.

Justice Ashok S. Kinagi, sitting singly at the High Court of Karnataka at Bengaluru, allowed a writ petition on 17 June 2026 and quashed a circular issued by the Registrar (Evaluation) of Karnataka State Law University (KSLU), Hubballi, to the extent it directed repeater students to appear for “Labour and Industrial Law-I” and “Labour and Industrial Law-II” in place of the Labour Law-I and Labour Law-II subjects under which they had been admitted and taught. The court found that directing students to sit examinations in subjects that were never taught to them was arbitrary and could not be sustained. Both sides agreed that the matter was governed by an earlier coordinate bench order, and the court disposed of the petition on that basis while issuing concrete directions to the university.

The Dispute Before the Court

The two petitioners — Ananda Karegoneppara, a student residing in Basavanagudi, Bengaluru, and Aarthi Raju of Indiranagar, Bengaluru — were enrolled in the three-year LLB programme under a syllabus that included Labour Law-I and Labour Law-II. They had attended classes in those subjects at B.M.S. College of Law, Bull Temple Road, Basavanagudi, Bengaluru, and had appeared for the corresponding examinations. Having failed, they became repeater students.

On 8 April 2026, the Registrar (Evaluation) of KSLU issued Circular No. KaRaakaaVi/Pariksha Vibhaga/2025-26/54. The circular introduced a revised syllabus and directed repeater students to appear for Labour and Industrial Law-I and Labour and Industrial Law-II in place of the subjects they had originally studied. The petitioners challenged this circular under Articles 226 and 227 of the Constitution of India, seeking a writ of certiorari to quash it and a writ of mandamus directing the university to conduct examinations in the original subjects for students admitted under the earlier syllabus.

Respondent No. 3, B.M.S. College of Law, was served with notice, but that notice was dispensed with by order dated 17 June 2026. Respondents 1 and 2 — the Vice-Chancellor and the Registrar (Evaluation) of KSLU — were represented by Smt. Saritha Kulkarni, advocate.

The Legal Issue

The core question was whether a university can, through a revised-syllabus circular, compel repeater students to appear for subjects that were never part of their instruction. The petitioners had been taught Labour Law-I and Labour Law-II. The college had not taught Labour and Industrial Law-I or Labour and Industrial Law-II. The circular, as applied to these students, effectively required them to be examined on content they had no opportunity to learn.

Senior counsel Sri S. Sreevatsa, appearing for the petitioners, submitted that the issue was squarely covered by the order of a coordinate bench of the same court in Sachin R. and Another v. Karnataka State Law University and Others, WP No. 34457 of 2024, disposed of on 17 December 2024. Counsel for the university did not contest this position and also submitted that the present petition should be disposed of in terms of that earlier order.

How the Court Reasoned

Justice Kinagi accepted the undisputed factual position: the petitioners were admitted under a syllabus containing Labour Law-I and Labour Law-II, they attended classes in those subjects, and they failed in the examinations conducted for those subjects. The revised circular then required them, as repeaters, to appear instead for Labour and Industrial Law-I and Labour and Industrial Law-II.

The court recorded a finding that the college had not taught Labour and Industrial Law-I and Labour and Industrial Law-II to the petitioners. On that basis, the court held that the respondent university cannot direct the students to appear for subjects which were not taught to them. Since the college had taught Labour Law-I and Labour Law-II, insisting that the petitioners appear for the revised subjects was arbitrary.

The reasoning is grounded in a straightforward principle: a student's examination obligation must correspond to the instruction actually received. Introducing a revised syllabus mid-stream and applying it retrospectively to repeaters who had already been taught under the old syllabus, without ensuring that the new subjects were also taught, creates an impossible situation for those students. The court treated this as arbitrary state action amenable to writ jurisdiction.

The coordinate bench decision in Sachin R. (WP No. 34457 of 2024) had already addressed the same issue, and both parties accepted its applicability. Justice Kinagi followed that precedent and proceeded to frame specific directions.

Directions Issued

The court quashed Circular No. KaRaakaaVi/Pariksha Vibhaga/2025-26/54 dated 8 April 2026 insofar as it applied to the petitioners. It then issued the following directions to the university:

• The respondents are directed to conduct examinations for the petitioners in Labour Law-I and Labour Law-II — the subjects in which they had appeared and failed — and not to insist that they appear for Labour and Industrial Law-I and Labour and Industrial Law-II.
• The respondents are directed to accept the examination fee from the petitioners and permit them to appear as repeaters in the ensuing examination in Labour Law-I and Labour Law-II.
• All pending interlocutory applications, if any, stand disposed of.

Outcome

Writ Petition No. 17879 of 2026 (EDN-RES) was allowed by Justice Ashok S. Kinagi on 17 June 2026. The circular dated 8 April 2026 issued by the Registrar (Evaluation), KSLU, was quashed to the extent it applied to the petitioners. The university was directed to conduct examinations in Labour Law-I and Labour Law-II for the petitioners as repeater students and to accept their examination fee for the ensuing examination.