Clerical error at the university’s end, admitted in its own affidavit, cannot be a reason to withhold a degree from a student who was admitted, attended classes and cleared every examination, the Supreme Court has held, directing Manav Bharti University to release a law graduate’s marksheets and degree within four weeks.
New Delhi: A name left off the university’s admission disclosure list was the university’s own clerical error, and the student it belonged to could not be made to suffer for it, the Supreme Court has held, setting aside a Himachal Pradesh High Court order that had left a law graduate to pursue a civil remedy for her withheld degree [Stuti Sharma v. Manav Bharti University (MBU) and Others].
The appeal was allowed by a Bench of Justice Vikram Nath, Justice Augustine George Masih and Justice Sandeep Mehta in a judgment dated September 24, 2026, authored by Justice Augustine George Masih. The judgment is marked non-reportable and cited as 2026 INSC 1117.
What the university told the Court
The university did not contest the mix-up. Its affidavit admitted that, because of a “clerical and inadvertent human error” by its previous administration, the appellant’s name was left out of the disclosure list and the name of one Pankaj Kumar was forwarded instead.
Kumar had been admitted separately in 2015 for the 2015-2020 session, so his inclusion was a clerical mismatch and not a substitution or deletion of Sharma’s admission. The university also affirmed that she had cleared all examinations of the 1st to 10th semesters.
How the degree came to be withheld
Appellant Stuti Sharma took admission in the five-year BA.LLB course at the university’s Department of Law for the 2016-2021 session under Admission No. R16BALLB0050 and Registration No. MBU-2016-0417. Detailed marks certificates were issued to her for the 1st to 6th semesters, but not for the 7th to 10th semesters, and she was never given her degree.
The trouble began after several cases were registered against the university’s then administration over allegations of sale of degrees, and its records were seized during the investigation. On a representation by students to the Chief Justice of the High Court, a public interest litigation was registered, and the State government set up a document verification committee chaired by the Superintendent of Police, Solan.
The committee checked whether students’ names appeared in the university’s Green Register and in the Admission Disclosure List sent to the Himachal Pradesh Private Educational Institutions Regulatory Commission (HP-PERC). By a letter of September 19, 2023, the university told Sharma that her name was in the Green Sheet Register for 2016-2017 but missing from the disclosure list, and that her documents therefore could not be issued.
The High Court’s order of January 7, 2025
Sharma approached the High Court through CWP No. 4620 of 2024, seeking her marksheets for the 7th to 10th semesters, her degree, character certificate and migration certificate. In the meantime, the High Court disposed of the PIL, observing that it could not decide disputed questions of fact about the status of students and leaving them free to approach the competent court. Her writ petition was disposed of in the same terms on January 7, 2025.
In the Supreme Court, her counsel argued that she had attended classes, paid all fees and passed every semester, and that sending her record to HP-PERC was the university’s job. Without a degree, counsel said, she could not enrol with the State Bar Council, pursue higher studies, sit competitive examinations or find work.
What the Bench held
The Court held:
“The exclusion of her name from the admission disclosure list is, on the university’s own admission, a clerical error at its own end in which the Appellant had no part, and the Appellant cannot be made to bear its consequences and suffer.”
A discrepancy between the result gazette and the Green Sheet for earlier semesters did not alter the position. The Bench noted that marks certificates for those semesters had already been issued, that neither respondent claimed she had failed any examination, and that her writ petition sought only the later documents.
“The Appellant has been deprived of her documents for no fault of hers for a substantial period of time, and that relegating her to a court of competent jurisdiction, as observed by the High Court vide the impugned order dated 07.01.2025, is not called for, as no factual dispute survives as to her entitlement.”
Four weeks to issue the documents
The order of January 7, 2025 was set aside as regards Sharma. The university must now issue her marksheets for the 7th to 10th semesters, her degree and other relevant documents, including the character certificate and migration certificate, within four weeks of receiving the judgment. There was no order as to costs.
Why the judgment matters
Students caught in regulatory crackdowns on institutions often find their own records frozen along with the institution’s. The ruling draws a clear line: where the university’s internal records and its own affidavit show a student was genuinely admitted and passed, a reporting slip at the university’s end is not a disputed fact that needs a civil trial.
For a law graduate, the cost of delay is concrete. Without a degree, there is no Bar enrolment, no postgraduate study and no job. By ordering release within four weeks instead of leaving her to fresh litigation, the Court treated the years already lost as reason enough to end the matter.
Case Title: Stuti Sharma v. Manav Bharti University (MBU) and Others [Civil Appeal No. 13122 of 2026, arising out of SLP (C) No. 12783 of 2026]; 2026 INSC 1117
Bench: Justice Vikram Nath, Justice Augustine George Masih and Justice Sandeep Mehta, Supreme Court of India
Date of Judgment: September 24, 2026
Impugned Order: High Court of Himachal Pradesh at Shimla, CWP No. 4620 of 2024, dated January 7, 2025