19 January 2026 Legal Updates

Right To Appear In Examination Is Akin To Right To Life Under Article 21: Allahabad High Court Orders Special Exam Due To Portal Glitch

(a) Case Title:

• Shreya Pandey v. State of U.P. & Ors.

(b) Court:

• Allahabad High Court

(c) Date of Decision:

• 17th January 2026

(d) Bench:

• Justice Vivek Saran

Facts of the Case

The petitioner, Shreya Pandey, was a first-year B.Sc. (Biology) student at Urmila Devi PG College, Prayagraj, affiliated with Rajju Bhaiya University. She had duly deposited her fees on July 16, 2025 and regularly attended classes for the academic session 2025–2026.

However, when the examination schedule was released, the University failed to issue her admit card. The reason cited was that her admission record was not updated on the University’s “Samarth Portal” within the prescribed time, though her application was available in draft form on the portal.

The College informed the University that records of nearly 30 students were not updated due to a technical glitch. While the records of 25 students were later rectified, the petitioner’s data remained unupdated, resulting in denial of her right to appear in the examination.

Aggrieved, the petitioner approached the Allahabad High Court under Article 226.

Issues Raised

• Whether denial of permission to appear in an examination due to technical/administrative lapse violates Article 21 of the Constitution?
• Whether a student can be penalised for failure of a digital portal despite no fault on her part?
• Whether courts can direct conduct of special examinations to protect students’ academic future?

Contentions of the Petitioner

• The petitioner had fulfilled all eligibility requirements, including fee payment and attendance.
• Denial of admit card was solely due to technical failure of the University portal, not attributable to her.
• Preventing her from appearing in the examination would irreversibly damage her academic future.
• Such denial violates Article 21, which includes the right to live with dignity and pursue education.

Contentions of the Respondent (University / State)

• The University contended that issuance of admit card was system-driven and dependent on timely updation of records on the portal.
• Since the petitioner’s record was not fully updated within the prescribed timeline, she could not be permitted to appear.
• No clear procedure was placed before the Court to address such technical glitches.

Court’s Reasoning & Key Findings

1. Education and Article 21:

• The Court held that the right to appear in an examination is akin to the right to life with dignity under Article 21.
• A student’s future cannot be sacrificed due to administrative inertia or technological lapses.

2. No Fault of the Student:

• The Court noted that the University had prior knowledge of the non-updation issue.
• The petitioner’s data existed in draft form, and authorities failed to act despite being informed.

3. Reliance on Judicial Precedents:

• Relied on:
   - Rahul Pandey v. Union of India (2025) – appearing in examinations held to be a fundamental right under Article 21.
   - Re: Master Prabhnoor Singh Virdi v. Indian School (Delhi HC, 2023) – denial of exam infringes right akin to right to life.

4. Accountability of Educational Authorities:

• Universities must have standard procedures to deal with portal-related errors.
• Students cannot be left remediless in a digitally driven admission system.

Final Verdict

• Petition Allowed (Interim Direction)
• University directed to:
  - Conduct a special examination for the petitioner within two weeks
  - Declare results within a reasonable time
  - Update petitioner’s records to secure her future
• University counsel directed to file a counter-affidavit explaining procedures for portal glitches
• Matter listed for February 10, 2026

Legal Principles Established

1. Right to Education & Article 21:

• Right to appear in examinations forms part of the right to life with dignity.

2. No Penalisation for Administrative/Technical Lapses:

• Students cannot be made to suffer for system failures beyond their control.

3. Digital Governance Accountability:

• Authorities must create robust grievance-redress mechanisms in online systems.

4. Judicial Protection of Academic Future:

• Courts can issue mandatory directions, including special examinations, to prevent injustice.