The bench of Justice SM Subramaniam and Justice N Senthilkumar observed that online classes would not be a substitute for physical mode of learning. The court added that AI tools like ChatGPT could never be equated with a qualified teacher and cannot teach aspects of integrity and morality, which are important aspects of the legal profession.

“Online classes provide an avenue for learning when need arises, but it cannot be a substitute for physical mode of learning. There are certain advantages that stem from regularly attending classes. It goes beyond mere acquisition of knowledge. It instills values of self discipline, punctuality, active classroom engagements, positive social behaviours etc. So online classes cannot be substituted with physical classrooms. Also neither Chat GPT nor any other Al tool can ever be equated with a qualified lecturer. Artificial intelligence can come as closer to human intelligence but cannot teach the aspects of integrity and morality that are also ethical pillars of legal professions. Such lessons can only be learnt in a vibrant classroom,” the court said.

The court observed that studying law connects students to society and gives them an opportunity to be a voice for the voiceless. The court added that legal education was not just a means to make money but requires a commitment to society. The court added that only classroom debates and dynamic social discussions would help in building legal ideas.

“Legal education is not just for making money but traverses beyond that. It requires a commitment to the society and to the Constitution thereby requiring the presence of collective and diverse voices of the students in a classroom. It is from classroom debates and dynamic social discussions that legal ideas and novelty emanates. Classrooms provide a platform for the students to debate and engage in productive discussions thereby creating a future for a generation of energetic and vibrant legal professionals,” the court said.

The court was hearing appeals filed by the Registrar of Tamil Nadu Dr Ambedkar Law University, Dean of School of Excellence in Law, Controller of Examination of Tamil Nadu Dr Ambedkar Law University seeking to set aside an order of a single judge.

Rule 12 of the Bar Council of India Rules mandates minimum attendance requirement, failing which a student should not be permitted to take the end semester test. A group of students, who had not fulfilled the mandatory minimum attendance percentage had filed writ petitions seeking directions to the respondent authorities to reconsider their decision asking the students to redo the academic year and instead permit them to write the end semester examination.

While allowing the plea partly, the single judge had directed the Bar Council of India to revisit the Rules of Legal Education. The court had also asked the authorities to permit the students to continue the course and write the examination. Against this order, the authorities had filed the present plea.

The bench noted that Rule 12 of the Bar Council of India Rules mandated a compulsory attendance of 70% and provided condonation of 5% of attendance with sufficient cause, bringing it down to 65%. The court added that the rules were clear and no further relaxation could be provided as it would defeat the purpose of the Rules itself.

The court also noted that Article 14 of the Constitution would be applicable in the case as a student, who attended classes regularly and secured the mandated attendance should not be made to feel that a different treatment was given to a few students.

The court added that in the present educational landscape, students were able to secure a seat of their choice after a lot of hardships. The court added that many times, students from financial and socially challenging backgrounds ended up taking alternative courses as they were unable to get the course of their choice. The court thus highlighted that a student should realise the value of the seat secured by them.

Thus, the court was inclined to allow the appeal and set aside the order of the single judge.

Counsel for Petitioner: Mr.A.Thiyagarajan, Senior Counsel for Mr.M.Nallathambi

Counsel for Respondents: Mr.P.M.Subramanian, Senior Counsel for Mr.Manoj Sreevalsan, Mr.S.R.Raghunathan, Standing Counsel for Bar Council of India, Mr.S.Bageerathan, Mr.B.M.Subash

Case Title: Shakthi Shyam v The Dean and Others

Citation: 2026 LiveLaw (Mad) 263

Case No: W.P.Nos.46137, 42461 and 43650 of 2025