The bench of Chief Justice SA Dharmadhikari and Justice G Arul Murugan noted that the fee paid by the student during her MBBS course was seized by the National Investigation Agency (NIA), holding that the fee was funded through Maoist activities.

The bench observed that if the student was in fact innocent, she could approach the Special Court for releasing the seized funds. The court added that the college could not be expected to litigate against the NIA to retrieve the fee.

“If the appellant maintains her absolute innocence and claims the funds were legitimate, her remedy lies in approaching the competent Special Court for the release of the seized funds from the NIA. She cannot compel a private educational institution to take on the burden of litigation against the NIA to retrieve the fees paid by the appellant, which was appropriated,” the court said.

The court added that while the student may not be an accused in the NIA case, she could not claim an equitable right to benefit from the fruits of crime.

The court observed that once the course fee was seized by the NIA, the student's account with the college would become legally defaulted to an unpaid status. The court noted that forcing the college to release the certificate, when it has, in effect, not received any fee from the student, would be a gross miscarriage of justice.

“While it may be true that the appellant is not directly arrayed as an accused in her individual capacity, she cannot assert an equitable right to benefit from the fruits of a crime. The moment the NIA seized and appropriated the fee amount from the college, the appellant's account with the institution legally defaulted to an unpaid status…Forcing the institution to release the certificates when it has effectively received zero clean currency for her education would be a gross miscarriage of equity and justice. In our firm view, the learned Single Judge rightly held that the fifth respondent college is not obligated to release the certificates until its rightful dues are reimbursed by clean, untainted means,” the court held.

The court was dealing with an appeal moved by a student, Puja Kumari, against the order of a single judge, dismissing her plea to direct the college and medical council authorities to release her course completion certificate and MBBS degree.

As per the facts of the case, during the student's tenure, Rs 1,13,70,500/- was periodically remitted to her account. Later, during the course of a criminal investigation, the NIA unmasked that the funds utilised to pay the student's fee was directly derived from illegal, extorted funds raised on behalf of Communist Party of India (Maoist), a proscribed terrorist organisation.

The NIA seized the funds after notice to the college. The college then withheld the student's documents over non-realisation of legitimate institutional fee.

The student argued that educational certificates could not be retained as security or treated like financial deposits under general lien. The student also denied any personal involvement or connection with any unlawful or terrorist organisation and pointed out that she had a clean, impeccable record and had clearer her medical curriculum without any blemish.

The court noted that the charge sheet submitted by the NIA had named the student's immediate family members, including her brother and paternal uncle as key operational masterminds raising extorted funds for a banned terrorist outfit.

The court added that the single judge's order had rightly protected the financial autonomy of the college, leaving it open for the student to deposit the requisite fee afresh and claim her certificates. Thus, finding no reason to interfere, the court dismissed the appeal.

Counsel for Appellant: Mr.Rakesh Kumar for Mr.T.S.Baskaran

Counsel for Respondents: Mrs.V.Sudha Senior Central Government Standing Counsel, Mr.U.Baranidharan, Mr.M.S.Krishnan Senior Counsel for Mr.T.Balaji

Case Title: Puja Kumari v Union of India and Others

Citation: 2026 LiveLaw (Mad) 267

Case No: W.A.No.2422 of 2025