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Supreme Court of India

ATUL KUMARversusTHE CHAIRMAN (JOINT SEAT ALLOCATION AUTHORITY) AND OTHERS

Citation
2024 INSC 749
Decided
30 September 2024
Disposal
Disposed off

Holding

A student who missed the fee‑payment deadline despite diligent efforts must be granted admission, and a super‑numerary seat may be created under Article 142 to ensure substantial justice.

Summary

The petitioner, a Scheduled Caste student, secured a seat in Electrical Engineering at IIT Dhanbad after ranking 1455 in his category in JEE Advanced 2024. He attempted to pay the required admission fee of Rs 17,500 before the 5 pm deadline on 24 June 2024, logging into the portal six times between 3:12 pm and 4:57 pm, but the payment was not processed due to the portal closing. Despite his diligent efforts and the availability of funds, he lost the admission because of the few‑minute delay. The Court examined whether the procedural deadline could be relaxed in view of the petitioner’s marginalized status and the principle of substantial justice under Article 142 of the Constitution. Finding no fault on the petitioner’s part and emphasizing the need to protect meritorious students from undue hardship, the Court ordered that a super‑numerary seat be created and the petitioner be admitted to the same batch, with all associated benefits. The order also directed the institute to facilitate his academic catch‑up for the elapsed period.

Issues considered

  • Whether a Scheduled Caste student who missed the online fee payment deadline by a few minutes is entitled to admission under the principles of substantial justice.
  • Whether the Supreme Court can invoke Article 142 to create a super‑numerary seat and override the admission deadline.
  • Whether the petitioner’s diligent attempts to pay the fee constitute sufficient compliance with the admission formalities.

Legislation cited

Subjects

IIT-AdmissionSchedule caste categoryElectrical Engineering courseMade efforts to log into the portalLost admission to IITLate in paying online admission fee by few minutesMarginalized group of citizensGranted admission to IITSupernumerary seat

Judgment

             [2024] 10 S.C.R. 150 : 2024 INSC 749

                      Atul Kumar
                            v.
The Chairman (Joint Seat Allocation Authority) and Others
                (Writ Petition (Civil) No 609 of 2024)
                            30 September 2024
 [Dr Dhananjaya Y Chandrachud, CJI, J B Pardiwala and
                   Manoj Misra, JJ.]

                        Issue for Consideration
   Matter pertains to Schedule caste category student who lost his
   admission to IIT since he was late in paying the online admission
   fee of Rs 17,500/- by a few minutes.

                               Headnotes†

   Constitution of India – Art. 142 – Exercise of power under –
   Indian Institute of Technology IIT-Admission – Schedule
   caste category student allotted seat in Electrical Engineering
   course at IIT – Took all steps to comply with all formalities
   pursuant to the allotment to him of a seat for the course,
   however, lost his admission to IIT since he was late in paying
   the online admission fee of Rs 17,500/- by a few minutes –
   Challenge to:
   Held: Petitioner logged in as many as on six occasions and
   uploaded the documents, which evidently indicates that he was
   making earnest efforts to log into the portal – No conceivable
   reason why the petitioner would not have done so if he had the
   wherewithal to pay the fees of Rs 17,500 – Talented student like
   the petitioner who belongs to a marginalized group of citizens
   and has done everything to secure admission should not be left
   in the lurch – Power of this Court u/Art.142 to do substantial
   justice is meant precisely to cover such a situation – Petitioner
   to be granted admission to IIT Dhanbad against the seat which
   was allotted to him in the branch of Electrical Engineering –
   Supernumerary seat to be created for the petitioner, if so
   required. [Paras 6, 7]

                               List of Acts
   Constitution of India.
[2024] 10 S.C.R.                                                          151

                      Atul Kumar v. The Chairman
              (Joint Seat Allocation Authority) and Others

                             List of Keywords
     IIT-Admission; Schedule caste category; Electrical Engineering
     course; Made efforts to log into the portal; Lost admission to IIT;
     Late in paying online admission fee by few minutes; Marginalized
     group of citizens; Granted admission to IIT; Supernumerary seat.
                            Case Arising From
     CIVIL ORIGINAL JURISDICTION: Writ Petition (Civil) No. 609 of 2024
     (Under Article 32 of The Constitution of India)
                         Appearances for Parties
     Amol Chitale, Sarthak Sharma, Mrs. Pragya Baghel, Advs. for the
     Petitioner.
     Sonal Jain, Ms. Kajal Sharma, Arjun Mitra, Advs. for the Respondents.
                Judgment / Order of the Supreme Court
                                   Order
1.   The petitioner is a meritorious student. He belongs to the Scheduled
     Caste category. He appeared for the JEE (Advanced) 2024 Examination
     and secured a rank of 1455 in his category. He was allotted a seat at
     the Indian Institute of Technology Dhanbad for a four year Bachelor
     of Technology course in Electrical Engineering. This was the second
     attempt and, therefore, the last chance for the petitioner to secure
     admission since only two attempts are permissible. The petitioner has
     disclosed that his father is a daily wager. The petitioner completed
     his higher secondary education from Khatauli, District Muzaffarnagar,
     Uttar Pradesh. The family income is below the poverty line.
2.   The time frame for the completion of online reporting, including the
     payment of fees and uploading of documents was till 5 pm on 24
     June 2024. The petitioner has stated that his parents arranged the
     funds required for the payment of fees. The fees were deposited
     in his brother’s account by 4.45 pm. The petitioner states that he
     logged into the portal of the first respondent at 4.45 pm and applied
     in the ‘float category’ of admission and uploaded the documents. The
     portal closed at 5 pm and his payment was not processed.
3.   The petitioner thereafter addressed an email to the first respondent. A
     response was received on 26 June 2024 from the IIT Bombay Office
152                                                          [2024] 10 S.C.R.

                       Digital Supreme Court Reports


       for JEE (Advanced) redirecting the candidate to the organizing IIT,
       which is IIT Madras. Eventually, these attempts did not bear any fruit.
4.     The petitioner approached the Jharkhand High Court Legal Aid Service
       Committee and he was directed to the Legal Services Committee
       of the Madras High Court. A writ petition was instituted before the
       High Court of Madras, but when the case came up for hearing, he
       was advised to approach this Court.
5.     The facts as they have been revealed before this Court indicate that
       there is no dispute about three critical aspects: (i) the allotment of
       the seat in Electrical Engineering to the petitioner at IIT Dhanbad; (ii)
       the Scheduled Caste status of the petitioner; and (iii) the steps which
       were taken by the petitioner to comply with all formalities pursuant
       to the allotment to him of a seat for the course.
6.     Counsel appearing on behalf of the first respondent has furnished
       to the Court the log-in details of the petitioner, which indicate that
       he was diligent in accessing the portal and did everything within
       his power to secure the realization of his admission. The petitioner
       logged in on 24 June 2024 between 15.12 hours and 16.57 hours,
       on as many as six occasions. This evidently indicates that he was
       making earnest efforts to log into the portal. There is no conceivable
       reason why the petitioner would not have done so if he had the
       wherewithal to pay the fees of Rs 17,500. A talented student like
       the petitioner who belongs to a marginalized group of citizens and
       has done everything to secure admission should not be left in the
       lurch. The power of this Court under Article 142 of the Constitution
       to do substantial justice is meant precisely to cover such a situation.
7.     We accordingly order and direct that the petitioner should be granted
       admission to IIT Dhanbad against the seat which was allotted to
       him in the branch of Electrical Engineering. The petitioner will be
       admitted to the same batch to which he would have been admitted
       in pursuance of the order of allotment. The petitioner is ready and
       willing to pay fees of Rs 17,500, which may be paid over personally
       at the time when admission is granted to him. A supernumerary seat
       shall be created for the petitioner, if so required, for the purpose of
       complying with this order and no existing student shall be disturbed in
       consequence. The petitioner would be entitled to all the consequential
       benefits of admission, including allotment of hostel accommodation
       and other facilities.
[2024] 10 S.C.R.                                                      153

                         Atul Kumar v. The Chairman
                 (Joint Seat Allocation Authority) and Others

8.   Since the admission of the petitioner has been delayed for no fault of
     his, we request the Director of IIT Dhanbad to use his good offices
     to ensure that the petitioner can duly complete the course work for
     the period which has already elapsed during this academic year.
     This will ensure that the petitioner is abreast of his class and does
     not suffer for the delay in granting him admission.
9.   The Petition is disposed of in the above terms.
10. Pending applications, if any, stand disposed of.

     Result of the Case: Writ Petition disposed of.



     †
         Headnotes prepared by: Nidhi Jain


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ATUL KUMAR versus THE CHAIRMAN (JOINT SEAT ALLOCATION AUTHORITY) AND OTHERS — 2024 INSC 749 - Legal Desk AI