WP/28421/2024 of P.Sheela Vs The State of Telangana on 24 June 2026

ORDER:

This Writ Petition is filed by the petitioner seeking the following relief: "...fo pass an order or issue any directions or issue any appropriate writ more particularly in the nature of WRIT OF MANDAMUS declaring the action of the 2nd respondent in rqecting the petitioners representation dated 25.04.2022 through vide MR No.117/PNAcad/F/OU/2022 dated 30 06 2022 which was submitted in compliance with the directions of this Honble Court in ifs order dated 18.04.2022 in W.P.No.16934 of 2022 as illegal This reiection has resulted in the cancellation of the petitioners PhD admission effectively nullifying her I 1/2 years of effort due to circumstances beyond her controlsuch as the COVlDl9 pandemic and the discontinuation of her supervisor due to health lssues Ihe petitioner had sought a oneyear extension to submit her PhD thesis w,hich was unjustly denied This rejection is unlawful afuitrary discriminatory and contrary to the principl,ts of natural justice as well as violative of Arlicles 14 and 21 of the Constitution of lndia Cctnsequently sel asrde the impugned Speaking Order issued under MR No 117/PR/Acad/F/OU/2022 dated 30 06 2022 and direct the 2nd respondent to appoint a new supervisor to enable the petition* to complete her remaining PhD thesis work and fufther extend the deadline for submittinl1 the petitioners PhD thesis by at least one year from the date of assigning the new supervisor and pass. . . "

02. Heard Mr. Ramesh Chilla, learned counsel for the petitioner, Sri Vamshi Kiran.tvl, learned Assistant Government Pleader appearing for respondent No.1 , and Sri Malipeddi Srinivas Reddy, learned Standing Counsel appearing for respondent No.2. Perused the record. 03(a) Aggrieved by the action of the 2nd respondent in rejecting the representation dated 25.04.2022 submitted by the petitioner pursuant to the directions issued by tltis Court in W.P. No 16934 of 2022. vide order dated 18.0t 2022, and the consequential cancellation of her Ph.D. adrnission, thereby

1. rendering futile her academic efforts spanning more than eight and a half years, the petitioner has flled the present writ petition 03(b). Learned counsel for the petitioner submits that the petitioner was admitted to the Ph.D. Programme in the Department of Genetics, Osmania University, on 06.02.2013 pursuant to proceedings dated 30.01.2013. lt is contended that the petitioner diligently pursued her research under the supervision of Professor A. Jyothi and successfully completed the substantial portion of her research work, besides complying with all academic and procedural requirements prescribed by the Unlversity. 03(c). Learned counsel further submits that during the course of her doctoral research, the petitioner and her family members were severely affected by the COVID-19 pandemic Owing to the resultant health complications, particularly the post- COVID ailments suffered by the petitioner, she was unable to complete and submit her thesis within the period of six months' extension granted by the University to research scholars admitted prior to the year 2016 Thereafter, the University extended the deadline for submission of theses up to 31 .O1 .2022. According to the learned counsel, after recovering from her health issues, the petitioner resumed her etforts to complete the thesis and was entitled to avail the benefit of a further extension up to 31 .03.2022, which was granted as a one-time rreasure in view of the extraordinary circumstances arising from the pandemic 03(d). lt is further contended that, at a cr.rcial stage of the research programme, the petitioner's Supervis;or, Professor A. Jyothi, who herself was facing serious health i:;sues, expressed her inability to continue as Supervisor and advir;ed the petitioner to seek a change of supervisron Accordingly, on 27.02.2022, the Supervisor issued a No Objection Certificate (NOC) consenting to the transfer of supervision. The said communicalion was received by the petitioner just one day prior to her scheduled Research Progress Seminar on 28.02.2022 03(e) Learned counsel submits that the petitioner, being left without a Supervisor, immediately submitted a representation dated 15.03.2022 lo lhe Vice-Chancellor seeking appointment of a new Supervisor and grant of extension of time 'br completion of her Ph.D. programme. However, no action wars taken by the University on the said representation, thereby compelling the petitioner to approach this Court by filing W.p. No 16934 ot 2022

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) 03(f). lt is further submitted that the University Grants Commission (UGC), through its Public Notice dated 01.12.2021, extended the last date for submission of theses by terminal M.Phil./Ph.D. students up to 30.06.2022 in view of the disruptions caused by the COVID-19 pandemic. Despite the said relaxation, the University failed to extend the benefit thereof to the petitioner. Learned counsel contends that closure of laboratories and restrictions imposed during the pandemic had severely hampered the progress of the petitioner's research work, thereby preventing her from completing the thesis within the stipulated time. 03(g). Learned counsel further submits that the petitioner had already completed more than 80% of her research work and had invested over eight and a half years in pursuit of her doctoral programme. However, due to circumstances beyond her control, namely the pandemic-induced disruptions and the sudden relinquishment of supervision by her Guide, she was unable to submit the thesis within the prescribed period. lt is contended that the absence of a Supervisor effectively prevented the petitioner from proceeding with the remaining academic formalities, including presentation of the requisite seminar and final submission of the thesis

03(h). lt is further submitted that this Court, while disposing of W.P. No.16934 of 2022, directed the University to consider the petitioner's request for appointment of a new Supervisor and grant of extension of time Pursuant thereto, the petitioner submitted a detailed representation dated 26.04.2022. ln lhe meanwhile, the UGC issued a notification dateri 01 .02.2021 and subsequently passed a Resolution dated 06.05.2022 authorising Universities and Higher Educational lnstitutions to grant further extensions to research scholars on a case{o-crase basis in view of the pandemic situation. However, accordinr3 to the learned counsel, the respondents failed to consider the petitioner's case in the light of the aforesaid UGC guidelines arrd the directions issued by this Court and instead proceeded to reject her representation by relying upon outdated regulaticns. 03(i). Learned counsel contends that the 2nd respondent failed to appoint a new Supervisor despite tlre No Objection Certificate issued by the erstwhile Supervisor anc notwithstanding the specific directions issued by this Court. Such inaction on the part of the University deprived the petitioner of the opportunity to complete the remaining academic requirements ernd continue her research work. Consequently. the petitioner has been unjusfly denied the opportunity to complete her Ph.D. programme despite having made substantial progress in her research. 03(J). lt is also contended that the action of the respondents is arbitrary and discriminatory inasmuch as, while seeking to cancel the petitioner's admission after a period of eight and a half years, the University had allegedly permitted several other research scholars to submit their theses after considerably longer periods ranging between 20 and 29 years. According to the learned counsel, such differential treatment is violative of Article 14 of the Constitution of lndia and cannot be sustained in law. Hence, according to the learned counsel for the petitioner, the petitioner ls entitled to a further extension of one year for submission of her Ph.D. thesis and completion of the doctoral programme. lt is therefore prayed to set aside the impugned proceedings rejecting the petitioner's representation and direct the respondents to appoint a new Supervisor and grant reasonable extension of time to enable the petitioner to complete and submit her Ph.D. thesis. 04(a). Respondent No.2 has filed a counter affidavit opposing the writ petition and contending that the relief sought by \

I the petitioner is contrary to the Ph.D. Rules and Regulations of Osmania University. lt is stated that, pursuant tc the interim order dated 18 04 2022 passed by this Court in W.P.lrlo.16934 ot 2022, the representation submitted by the petitioner ,seeking extension of the duration of her Ph.D. registration by one year was duly considered by the competent authorities. Hcwever, the same could not be acceded to in view of the statutory provisions governing Ph.D. admissions and registrations 04(b). lt is contended that, under Rule 12(2) of the Ph.D Rules and Regulations of Osmania Univerrsity, upon the recommendations of the Superviso(s), the Chairperson and the Head of the Department, the Dean may grant extension of the Ph.D. registration of a candidate for a period n,)t exceeding one year at a time, subject to an overall maximum extension of four

(4) years in the case of full-time research scholars and three (3) years in the case of part-time research scholars. The said Rule further stipulates that the registration of a rrlsearch scholar, whether full{ime or part{ime, shall automaticalll, stand cancelled upon expiry of the maximum permissible period cf eight (8) years.

04(c). Respondent No.2 further submits that, after the expiry of the maximum period of eight years, the Ph.D. thesis of a candidate cannot be accepted under any circumstances. lt is stated that a candidate whose registration stands automatically cancelled upon completion of the prescribed maximum period may seek fresh admission into the Ph.D. programme by undergolng the admission process afresh, including attendance of Ph.D. course work and completion of the prescribed course work examination. Such a candidate, however, forfeits any claim to hostel accommodation. 04(d). lt is further stated that, in view of the extraordinary circumstances arising out of the COVID-19 pandemic and pursuant to the UGC Public Notice bearing F.No.1-1012020 (CPP- ll), dated 16.03.2021, the University had extended the last date for submission of M.Phil./Ph.D. theses vide proceedings dated 31.12.2021 in respect of all candidates who were eligible to submit their theses by 31 .12.2020 and thereafter, subject to compliance with the applicable Rules and Regulations governing their respective batches.

04(e). Respondent No.2 further submits,:hat, in the interest of research scholars, the University issued proceedings dated 28.11.2021 extending the last date for submission of ph.D. theses by one month, i.e., up to 31.01 .2022, lty way of a grace period. Thereafter. vide proceedings dated 2AOj.2022, the said deadline was further extended from 31 .01 .2022 to 31 .03.2022 as a "one{ime chance" in view of the continuirrg effects of the COVID-19 pandemic. 04(0 lt is contended that, despite the Lniversity granting sufficient opportunities and extensions for submission of the thesis, the petitioner failed to submit her thesis within the stipulated time. Therefore, having failed to comply with the prescribed time limits, the petitioner cannot c:laim any further extension as a matter of right. Respondent No.2 further relies upon the remarks furnished by professor A. Jyo.:hi, the Research Supervisor of the petitioner, According to the said remarks, the petitioner had not been attending the lnstitute r;ince December, 2018. lt is stated that the petitioner had presentr:d her Research Design Seminar in March, 2015, however, she did not present the subsequent'Seininar as her research work had not been completed within the prescribed time frame.

7\ Oa(g). lt is further contended that the petitioner remained absent for nearly three years without informlng her Research Supervisor. Thereafter, after a considerable lapse of time, she reappeared and expressed her intention to submit the thesis solely on account of the deadline fixed by the University authorities. The Research Supervisor also informed the Dean that, in the circumstances, it was not feasible to scrutinize, verify and make necessary corrections to the thesis within a period of two weeks. Hence, the petitioner failed to comply with the mandatory requirements of the Ph.D. programme and the applicable Rules and Regulations governing thesis submission. lt is therefore submitted that no illegality or arbitrariness can be attributed to the action of the University in rejecting the petitioner's request for extension and that the writ petition is devoid of merit. Accordingly, he prayed for dismissal of the writ petition.

05. Having considered the submissions made by the learned counsel on either side and upon perusal of the material available on record, the undisputed facts reveal that the petitioner was admitted into the Ph.D. programme in the Department of Genetics, Osmania University, pursuant to proceedings.dated

30 01.2013. As per Rule 12(2) of the ph.D. Rules and Regulations of Osmania University, the registration of a research scholar automatically stands cancelled upon expiry of the maximum permissible period of eight years; and, thereafter, submission of a Ph.D, thesrs cannot be acc;epted under any circumstances. The said Rule further provides that a candidate whose registration stands cancelled may seek f.esh admission by complying with the prescribed requirements.

06. lt is not in dispute that the petitioner completed eight years from the date of registration during the year 2021 . However, in view of the extraordinary situation arising out of the COVID-19 pandemic, the University grantec relaxation and extended the last date for submission of Ph.D. thesis from time to time. lnitially, the benefit of the UGC public Notice dated 16.03.2021 was extended to eligible candidates. Thereafter, the University granted a grace period up to 31 .01 .2022 and subsequently by Order dated 28,0't .2022 exlen<jed the last date for submission of thesis up to 31 .03.2022 as a ,,One Time Chance". For proving her contention that she was affected by COVID-19. the petitioner relied upon a medical certificate issued by Shraddha Hospital. However, a perusal of thr-. said certificate tr reveals that she was merely advised to take bed rest for a period of one week. Therefore, the certificate, by itself, is insufficient to establish that the petitioner was incapacitated for such a prolonged period as to prevent her from completing and submitting her Ph.D. thesis within the extended time granted by the University.

07. lt is the case of the petitioner that she was unable to submit the thesis on account of the COVID-19 pandemic, health complications suffered by her and her family members, closure of laboratories, and the inability of her Supervisor, Professor A. Jyothi, to continue supervision on medical grounds. However, the material placed on record does not establish that the petitioner was diligently pursuing her research work throughout the relevant period. On the contrary, the counter affidavit discloses that, as per the remarks of the Research Supervisor, the petitioner had not attended the lnstitute since December, 2018. lt is further stated that the petitioner had presented her Research Design Seminar in March, 20'l 5 and thereafter did not present the subsequent seminar on the ground that her research work was not completed. The Supervisor specifically recorded that the petitioner remained absent for nearly three years without informing the Supervisor and, after a considerable lapse of time, sought to submit the thesis only when the University had prescribed a final deadline. l-hese factual assertions have not been effectively controverted by the petitioner.

08. Further. the record discloses that the petitioner sought change of Supervisor only at the fag end of the extended period granted by the University. The inability of the existing Supervisor to continue guidance at such a belerted stage cannot confer upon the petitioner any vested right to s;eek an indefinite extension of her registration contrary to the stertutory Rules and Regulations governing the Ph.D. programme. Therefore, the contention of the petitioner that she was prevented from submitting her thesis solely because her Supen,isor issued a No Ob.lection Certificate on 27.02.2022, has no water. 09 The communications issued by the UGC merely enabled Universities to consider grant of extelsion of time in appropriate cases. They neither mandated grant of extension as a matter of right nor overrode the statutory F,h.D. Rules and Regulations framed by the University. The question as to whether - a particular candidate is entitled to extension of time squarely falls within the academic domain of the University authorities.

10. lt is a settled principle of law that Courts exercising jurisdiction under Article 226 of lhe Constitution of lndia ordinarily refrain from interfering with academic decisions unless such decisions are shown to be arbitrary, mala fide, irrational, or in violation of any statutory provision. ln the present case, the impugned proceedings dated 30.06.2022 disclose that the representation submitted by the petitioner was duly considered by the competent authorities in the light of the applicable Rules and Regulations. The request was rejected primarily on the ground that the maximum permissible period prescribed under the Ph.D Regulations had already expired and that no further extension could be granted under the governing Regulations.

11. lt is also pertinent to note that the petitioner had earlier initiated contempt proceedings in C.C.No.829 ol 2022 alleging deliberate violation and wilful disobedience of the order dated 18.04.2022 passed in W.P.No.16934 of 2022. The said contempt case was subsequently closed by order dated 12 10.2022. This fact further demonstrates that the grievance 1.6 regarding non-consideration of her representation had already been agitated before the approprtate forum

12. ln view of the above discussion, tl'ris Court is of the considered opinion that the petitioner has failetj to establish any illegality, arbitrariness, mala fides or violatiorr of principles of natural justice in the impugned proceedtngs rlated 30 06.2022 warranting interference under Article 226 of tlre Constitution of lndia

13. Accordingly, this Writ Petition is dismissed. There shall be no order as to costs As a sequel, pending miscellaneous aplrlications, if any, shall stand closed /TRUE COPY/ SD/. A.I.I.S.GOWRI SHANKAR AS:3ISTANT REGISTRAR

SECTION OFFICER To, TKS

1. One CC to SRl. RATMESH CHILLA Advocate [OPUC]

2. ]woCCstoGF,r'onEDUCAT|oNHighcourtfortheStateofTelirngana,at HyclerrabacJ IOUTI ^ ^ FF^n\, 6,

3. ,Ore CC to Sni. illnltprOD SRINIVAS REDDY SC FOR OU [OPUCI

4. Two CD CoPies BNT @

HIGH COURT DATED: 2410612026

ORDER

CC TOD ttE S'Ia I€r

J)J JUr 2026 a -h i * D WP.No.28421 of 2024 DISMISSING THE WRIT PETITION WITI.IOUT COSTS I

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