IIM-Ahmedabad Moves Gujarat High Court Against Order Quashing Expulsion Of Students

IIM-Ahmedabad has moved the Gujarat High Court challenging a single judge's order quashing the institute's expulsion of three students enrolled in Doctoral of Programme in Management course wherein it was held that the action was not in consonance with the procedure prescribed in the programme manual.

During the hearing on Tuesday (January 6) the court orally asked the institute to show the provisions in the programme manual which permits the institute to ask students to leave within the first year (of the programme) when stage 1 of the programme–i.e., coursework–is of 2 years. 

The respondents (petitioners before the single judge) who were selected for Doctoral of Programme in Management (DPM) at IIM Ahmedabad, had challenged a June 7 decision which held that they had not fulfilled the conditions for promotion from first year to the second year of 'Coursework' stage. Hence their candidature in the said course was withdrawn and the petitioners were expelled from the programme. Against the single judge's order which set aside the expulsion, the institute had moved the division bench in appeal. 

During the hearing today, the counsel appearing for appellant IIM-Ahmedabad submitted before a division bench of Chief Justice Sunita Agarwal and Justice DN Ray referred to Clause 6.1.b of the manual which states:

"A student who has failed (i) to qualify for promotion from one stage to the subsequent stage of the programme, or (ii) to complete the programme in the stipulated time, will be required to leave the programme". 

She submitted that the programme is a four year course, which can be extended to 6 years. "It is in three stages. Stage 1 course work, Stage 2 is area comprehensive exam, and stage 3 is thesis and assistance. It is at that stage (stage 3) that the student identifies the subject of research. Till that time it is all preparation for identification of thesis".

The court asked if the students had been expelled at stage 1 itself, to which the counsel answered in the affirmative. 

The court was told that the three students were at work stage. As per the manual, the Coursework requirement is to be completed in two years and is spread across six terms, including an Orientation and Induction Module at the beginning of the Programme.

The court orally noted, "Total programme is of 4 years which can be extended to 6 years. These students are in first year. They have not even reached completion of stage 1. If they are in first year and stage 1 is coursework. Coursework requirement 4.3.1 it says it has to be completed in 2 years and is spread across six terms. Now stage 1 is coursework as per design of course". 

Referring to Clause 6.1.b the court orally said, "A student who has failed to qualify for promotion from one stage to the subsequent stage of the programme. So stage 1 to stage 2 will come only after two years. This is what we are reading from the manual. What we are saying is that even your manual says that only those students who have failed to qualify for promotion from one stage to subsequent means from stage 1 to 2 or 2 to 3 they will be asked to leave...Your clauses itself say that stage 1 coursework is to be completed in two years. They have not even completed 2 years..."

Referring to clause 6.2.3 which states that "a student declared not qualified for promotion at any stage of the programme, or not eligible for award of the title will be required to leave the Programme unless otherwise recommended by the Programme EC", the court orally said:

"'Not qualified for promotion at any stage'...how do you assess? Unless and until you give the period. Show us the provision which permits you to ask students to leave within one year".

The counsel referred to overall design of the coursework in Clause 7.1.1. The court at this stage referred to Clause 6.1.b and orally said that the provision does not talk of promotion from first year to second year.

"It talks of promotion from stage 1 to stage 2. One stage to another stage. So promotion from first year to second year during the stage 1 will not be a reason to...Expulsion of student of an academic rules has to be guided by rules or manual. The manual you placed before us does not permit you...Show us the provision. We are not concerned with grades or credits to be given for promotion from first year to second year. We are only on one question whether you can expel the student if he is not able to attain the marks in the first year," the court added. 

On clause 6.2.3 the court said, "It states 'not qualified for promotion at any stage of the programme'. So that means promotion is stage wise. Expulsion from programme is permitted only if the student has failed to clear the stage of programme. The first stage is coursework which is of 2 year duration. So unless and until the 2 years is completed you cannot argue that student is not fit for promotion". 

Meanwhile the counsel contended that the manual should not be read like a statute; to this the court orally remarked that for any study programme, whatever is manual, rules, regulations, they are framed by the particular authority it is to be read as statute. 

Then counsel then said, "Let me concede that it is to be construed strictly. Even then I will be taking the court through provisions to show how the word 'stage' is used and what is the requirement". 

She said that if the single judge's decision is accepted the result is that even if a person fails in every components, the person has to be with us for three years.

After hearing the matter for some the court listed the appeal on January 13. 

Case title: INDIAN INSTITUTE OF MANAGEMENT, AHMEDABAD & ORS. v/s ATUL KUMAR KAMESHWAR PRASAD GUPTA and batch

R/LPA/1336/2025 and connected appeals