Punjab & Haryana HC Sets Aside IIT Ropar's Same-Day Acceptance of PhD Student's Resignation, Finds It Was Not Voluntary

Justice Kuldeep Tiwari held that IIT Ropar acted with “lightning speed” to accept a PhD student's resignation without addressing her harassment complaints, making the resignation non-voluntary and liable to be withdrawn.

The High Court of Punjab and Haryana at Chandigarh has set aside the order dated 22 November 2025 by which the Indian Institute of Technology, Ropar accepted a PhD student's resignation on the very same day it was submitted. Justice Kuldeep Tiwari, sitting singly, found that the resignation was not a voluntary act but was submitted under compelling circumstances after the Institute failed to act on the student's harassment complaints against faculty members. The court directed IIT Ropar to allow the petitioner, Fatima Maqsood, to continue her Ph.D. Chemistry Programme forthwith. The judgment also requests the Director of IIT Ropar to create an atmosphere in which the petitioner can re-settle and complete her studies.

The Dispute Before the High Court

Fatima Maqsood enrolled in the Ph.D. Chemistry Programme at IIT Ropar in 2025. According to the petition, everything proceeded without incident until October 2025, after which she began facing harassment from faculty members on account of demands relating to research supervision.

On 21 November 2025, she sent an email complaint to the Director of IIT Ropar requesting strict action against named faculty members — Dr. Mandal, Dr. Tharamani, Dr. Arun, Mr. Deepak, Ms. Gargi, Dr. Naidu, Dr. Charanjit, and Dr. Reena — as well as an inquiry against her Doctoral Committee members for alleged conspiracy. The complaint noted that the Director had already reprimanded the faculty members but that the behaviour had continued.

When no action was taken on that complaint, Maqsood submitted her resignation the following day, 22 November 2025, by email. Her resignation letter stated that she was resigning due to “continued misbehavior and misconduct” and that the conduct had caused harassment to both her and her 67-year-old father. The resignation was recommended by her Supervisor, endorsed by the Head of the Department, and accepted by the competent authority — all on the same day.

The writ petition under Article 226/227 of the Constitution of India challenged the order dated 22 November 2025 accepting that resignation.

The Procedural Issue: Mandamus or Certiorari

IIT Ropar raised a preliminary technical objection: the petition's prayer sought only a writ of mandamus, whereas the order dated 22 November 2025 had not been formally challenged. The court appointed Mr. Amit Kumar Goyal as Legal Aid Counsel by order dated 18 May 2026. Mr. Goyal acknowledged that the petition had not been happily drafted by the earlier counsel and made an oral request to amend both the head note and the prayer clause so that the petition would also seek a writ of certiorari for quashing of the order dated 22 November 2025.

Justice Tiwari allowed the amendment, observing that a purely technical or clerical error should not be allowed to defeat the petitioner's case. The Registry was directed to carry out the requisite corrections in both the prayer clause and the head note.

IIT Ropar's Objections and the Court's Responses

Counsel for IIT Ropar raised two further objections. First, the Institute contended that the petition concealed material facts: after resigning from IIT Ropar, Maqsood had taken admission at CSIR Indian Institute of Integrative Medicine, Jammu, and the Institute had also received communications regarding her alleged conduct of making complaints against faculty and students there as well.

Justice Tiwari rejected this objection. The court held that subsequent events had no relevance to the legality of the order dated 22 November 2025, which was the subject of challenge. Even if those facts had been disclosed, they would not affect the assessment of whether that order was legally valid.

Second, the Institute argued that most of Maqsood's complaints had been redressed, that she had been given a guide of her choice on three occasions, and that the resignation was therefore entirely voluntary. Counsel pointed to a meeting on 3 August 2025 convened by the Director, at which Dr. Tharamani had spoken with Maqsood about her well-being and research programme, and to which she had agreed. The Institute also referred to an email dated 29 September 2025 raising concerns about frivolous emails sent by the petitioner. On this basis, the Institute submitted that it had no intention of revoking the resignation and that the petition should be dismissed.

The court also noted that on a previous date of hearing, the Institute had raised the issue that Maqsood was habitual of filing complaints against faculty, guides, and fellow students. In response, Maqsood — who was present in court — undertook to file an affidavit with the Institute stating that she would not press her earlier complaints and would not indulge in such activities in future. An affidavit dated 25 May 2026 was placed on record, in which she undertook not to make any complaint by email or otherwise against anyone within the Institute and to focus on her studies. The Institute's counsel, however, stated that despite the undertaking, the Institute wished to contest the petition on merits.

How the Court Reasoned on Voluntariness

Justice Tiwari posed a specific query to the petitioner's counsel: had Maqsood ever been served any notice for misconduct? Counsel fairly conceded that she had not. The court recorded that there was no complaint against the petitioner for misconduct or indiscipline, and that the Institute had neither contemplated nor taken any disciplinary action against her. The only grievance of the Institute was the filing of multiple complaints against faculty and fellow students.

The court drew on two precedents cited by the petitioner's counsel. In Writ Petition (Civil) No. 1137 of 2018, Ms. X v. Registrar General, High Court of Madhya Pradesh and another, decided on 10 February 2022, the Supreme Court had allowed a judicial officer's resignation to be withdrawn after finding it was not voluntary, and had observed that High Courts should counsel officers before accepting resignations. In Smt. Anita Tiwari v. State of U.P. and three others, decided by the Allahabad High Court on 7 January 2025, it was held that attending circumstances must be examined to determine whether a resignation was voluntary or not.

Applying that framework, Justice Tiwari found that the resignation letter was not a resignation simpliciter. Its contents showed it was submitted under compelling circumstances: the complaint of 21 November 2025 had never been redressed; the Institute had not found the complaints to be false after any inquiry; and the resignation was submitted the very next day after the complaint went unaddressed. The Supervisor, instead of taking care of the student's future, recommended acceptance on the same day. The Head of Department endorsed it, and the Registrar accepted it — all within the same day.

The court observed that this sequence reflected that the Institute “was in a hurry to get rid of the petitioner.” The objections raised before the court further confirmed that the Institute still did not wish the petitioner to rejoin and was attempting only to remove her rather than support her continuation.

Justice Tiwari declared that the resignation was not voluntary but was submitted under compelling circumstances, and that the petitioner had every right to withdraw it. The court held that her request for withdrawal ought to have been accepted, but instead had been kept pending for approximately three months, compelling her to approach the court.

Order

Justice Tiwari allowed the writ petition. The order dated 22 November 2025 accepting Maqsood's resignation was set aside. A writ of mandamus was issued directing IIT Ropar to allow her to continue her Ph.D. Chemistry Programme forthwith.

The court directed that Maqsood shall adhere to the undertaking she gave to the Institute. In the event of any violation, the Institute would be at liberty to take appropriate disciplinary action against her.

The court also requested the Director of IIT Ropar to sympathetically consider all the circumstances and try to create an atmosphere allowing the petitioner to re-settle and complete her studies, given the conduct of the Institute in hotly contesting the litigation.

Justice Tiwari recorded appreciation for Mr. Amit Kumar Goyal, Advocate, for assisting the court as Legal Aid Counsel on short notice.