Supreme Court Orders University to Release B. Pharma Degree Withheld Over Cancelled Caste Certificate
A Division Bench of Justices B.V. Nagarathna and Manmohan directed Sant Gadge Baba Amaravati University to announce semester results and issue the degree certificate to a student whose documents were withheld after her Scheduled Tribe caste certificate was cancelled.
The Supreme Court on 3 August 2026 allowed two civil appeals filed by Cynthia Julious Charlie against the Bombay High Court, Nagpur Bench, directing Sant Gadge Baba Amaravati University to announce the results of her 6th and 8th semester examinations, issue her B. Pharma degree certificate if she qualifies, and return all original testimonials held by the University. The University must complete this exercise within three weeks of receiving the certified copy of the order. The decision follows the Court’s earlier rulings in Ajay Dattatraya Bandewad v. State of Maharashtra & Ors., C.A. 6637/2025, and Mrudula v. State of Maharashtra and Ors., SLP(C) No. 15902/2023, both decided on 13 May 2025 and 13 May 2024 respectively.
How the Dispute Reached the Supreme Court
Cynthia Julious Charlie was admitted to the Four-Year Full-Time Degree Course in Pharmacy (B. Pharma) at a college affiliated to Sant Gadge Baba Amaravati University in the Scheduled Tribe category for the academic year 2014–2015. At the time of admission, the college communicated to her that she was eligible for admission from the open category. Acting on that communication, she paid fees at the rate applicable to open-category students.
On 31 May 2017, the Caste Scrutiny Committee cancelled her caste certificate. The Committee found that she had failed to furnish any material or document to substantiate her claim of belonging to the ‘Gond’ Scheduled Tribe. Despite completing the B. Pharma programme in 2018, the University and the college withheld her 6th and 8th semester mark sheets and her degree certificate, citing the cancellation of her caste certificate.
Aggrieved, she filed Writ Petition No. 1610 of 2020 before the Bombay High Court at Nagpur. The High Court dismissed it on 27 June 2022. It observed that she had been given an opportunity to produce a valid caste certificate but had not done so. It further held that under the rules of the Directorate of Technical Education, her admission could not be converted to an open-category admission in those circumstances.
After that dismissal, the Principal of the respondent college issued a no-objection certificate dated 6 October 2022. The Principal communicated to the University Registrar that the appellant had been admitted in the open category from 2014–2015 to 2018–2019, had paid all fees and dues, and that her withheld documents could be released. The appellant then served a legal notice on the University demanding release of her mark sheets and degree certificate.
The University did not comply. The appellant filed a second writ petition, Writ Petition No. 4763 of 2024, before the same Bench at Nagpur. The High Court dismissed it on 7 February 2025, holding that the earlier writ petition had already attained finality since it was not challenged before the Supreme Court. The court added that the no-objection certificate of 6 October 2022 had in any case been withdrawn by a communication dated 14 October 2024, and that the Principal was not the person who had granted admission, so the certificate could not generate a cause of action. It also held that paying open-category fees alone did not entitle the appellant to relief.
She then filed two special leave petitions before the Supreme Court, challenging both the 2022 and the 2025 orders. The Court condoned the delay in approaching it against the 2022 order, given that both petitions arose from the same cause of action, and granted leave.
The Court’s Directions and the Governing Precedent
The Division Bench, comprising Justice B.V. Nagarathna and Justice Manmohan, allowed both appeals and disposed of them in terms of its earlier orders in Ajay Dattatraya Bandewad v. State of Maharashtra & Ors. and Mrudula v. State of Maharashtra and Ors. Those precedents, decided on 13 May 2025 and 13 May 2024 respectively, appear to have addressed comparable situations involving withheld academic documents and cancelled Scheduled Tribe caste certificates in Maharashtra.
The Court directed the University to announce the results of the 6th and 8th semester examinations taken by the appellant. If she has qualified, the University must issue the degree certificate and return all original testimonials in its possession. The three-week deadline runs from the date of receipt of the certified copy of this order.
Conditions Placed on the Appellant
The order is not unconditional. The Court imposed two specific restrictions on the appellant going forward.
First, she must not place any reliance on the caste certificate indicating membership of the Scheduled Tribe category. That certificate has been cancelled by the competent authority and declared invalid in law. The restriction applies to any future studies and to public employment.
Second, she must not take any step to obtain a fresh certificate on the basis that she belongs to the Scheduled Tribe category.
The appellant’s counsel also placed on record at the outset that she was not pressing any prayer for compensation. The Court noted this submission.
Outcome
Both civil appeals are allowed and disposed of. The Bombay High Court orders dated 27 June 2022 and 7 February 2025 in Writ Petition No. 1610 of 2020 and Writ Petition No. 4763 of 2024 are set aside to the extent necessary to give effect to the Supreme Court’s directions. Sant Gadge Baba Amaravati University must announce the 6th and 8th semester results, issue the degree certificate if the appellant has passed, and return all original testimonials within three weeks of receiving the certified copy of the order. All pending applications in the matter stand disposed of.