The Madras High Court issues a significant ruling on Tamil Nadu Dr. Ambedkar Law University’s PhD admission criteria, emphasizing alignment with UGC standards. The decision, prompted by a challenge to Clause 3.1 of the university’s regulations, addresses concerns of exclusion and compliance with UGC guidelines.
Thank you for reading this post, don't forget to subscribe!CHENNAI: On Tuesday(12th March), The Madras High Court has made a important ruling concerning the PhD admission criteria set by the Tamil Nadu Dr. Ambedkar Law University. The court’s decision, delivered by the first bench comprising Chief Justice SV Gangapurwala and Justice D Bharatha Chakravarthy, has brought into focus the alignment of university regulations with the standards set by the University Grants Commission (UGC).
The controversy centered around Clause 3.1 of the Tamil Nadu Dr. Ambedkar Law University Ph.D. Regulations, 2020, which mandated that only candidates with a two-year Master’s degree in law were eligible for admission to the PhD program. This stipulation was challenged in the High Court by Suganya Jeba Sarojini, a law graduate who argued that the regulation was exclusionary and contradicted UGC guidelines.
Suganya Jeba Sarojini’s legal journey began after she graduated in Law from Dr. Ambedkar Government Law College, Chennai, in May 2015 and completed her Post Graduation – LL.M. (Human Rights) Degree from Amity Institute of Advanced Legal Studies, Amity University, New Delhi in 2016 with a CGPA of 8.08. Her academic journey continued as she cleared the National Eligibility Test for Assistant Professor (Law) in December 2018 and subsequently started working at the Tamil Nadu Dr. Ambedkar Law University on a contract basis from July 2019.
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The Sarojini’s argument was the “Guidelines for Introduction of one-year LLM Degree Program, 2012” issued by the UGC, which recognized the one-year LLM program. She contended that many central and state universities, along with premier law schools, had already transitioned to this new structure, thereby making the university’s two-year requirement outdated and unjustifiable.
The university defended its position by arguing that the one-year and two-year LLM programs were not equivalent, citing the Bar Council of India’s regulations, which suggested that the one-year program was a temporary measure. However, this stance was challenged by the fact that the UGC, a paramount body in determining educational standards, had validated the one-year LLM as a legitimate qualification.
In their ruling, the judges noted:
“if by an admission regulation, the Universities mandate that they will admit candidates with only 3-year law or 5-year law alone or 1 year LLM or 2 Year LLM alone, it does not mean ‘higher standards’, but it would be considered impinging upon the jurisdiction of the University Grants Commission and would accordingly be ultra vires.”
The bench further clarified that the university’s argument of prescribing higher qualifications did not hold since-
“the rule does not prescribe greater qualification, as the two-year LLM is not a higher qualification than the one-year LLM as both get the same degrees. Prescribing higher standards would be in ‘addition to’ and not in ‘derogation to’. It can be supplementing and not supplanting.”
Ultimately, the court concluded that the regulation, by excluding one-year LLM holders, was not in alignment with the broader educational standards set by the UGC. The judges stated-
“The fallacy is severable and the regulation is workable even in the absence of the said words and is accordingly read down.”
As a result, the Madras High Court directed the Tamil Nadu Dr. Ambedkar Law University to admit Suganya Jeba Sarojini to the PhD program, allowing her to pursue her research in accordance with the university’s rules and procedures, thereby setting a precedent that could influence future educational regulations and admissions criteria across the state and potentially beyond.

