Vijay Institute Of Management vs. The Registrar

Facts

The petitioner, Vijay Institute of Management, sought an extension of affiliation from Anna University for its Master of Business Administration (MBA) course for the academic year 2019-2020. The university had initially issued a deficiency letter on April 5, 2019, citing three deficiencies, including issues with the library. The petitioner submitted a compliance report on April 22, 2019, claiming all deficiencies were rectified. However, the university rejected the affiliation request on May 11, 2019, stating the library deficiency persisted. The petitioner submitted further proof of compliance, including purchase bills for library books, on May 18, 2019. Despite this, the university issued a consequential order on May 21, 2019, rejecting the affiliation and placing the institution under a 'no admission' category for the MBA program.

Held

The Court held that the University's rejection of the petitioner's application for extension of affiliation was unjustifiable, arbitrary, and a colourable exercise of power. The Court found that the University's insistence on specific titles for the 10 additional books to be added to the library was unreasonable, especially since the University itself had not prescribed such specific titles. The Court noted that the petitioner's library already possessed 3134 books, significantly exceeding the requirement of 1080 books. The Court also observed that the petitioner had indeed purchased additional books and journals, and the University had not provided a specific format for the bills and vouchers. Therefore, the Court quashed the impugned orders dated May 11, 2019, and May 21, 2019. The University was directed to issue an order granting extension of affiliation for the MBA program with an intake of 120 students for the academic year 2019-2020 within one week.

Key Issues

1. Whether the University's rejection of the petitioner's application for extension of affiliation for the MBA program for the academic year 2019-2020 was arbitrary and unsustainable in law, given the petitioner's compliance with the stated deficiencies. Petitioner's Arguments: - The petitioner contended that all three deficiencies, including those related to the library, were rectified and a compliance report was submitted on April 22, 2019. - They argued that subsequent submissions on May 18, 2019, with proof of purchase of additional library books, further demonstrated compliance. - The petitioner asserted that the university mechanically reiterated the same reasons for rejection without proper consideration, rendering the impugned orders unsustainable. Revenue/State's Arguments: - The respondent University argued that the scrutiny committee was not satisfied with the compliance report regarding the library deficiencies. - Specifically, the University contended that the invoices submitted by the petitioner for the purchase of additional books and journals were not for the specific titles prescribed by the University.