Priyanka Kumari and Ors. v. The State of Bihar and Ors.
The case is between Priyanka Kumari and The State of Bihar, embodying a critical question of Law, i.e., whether the termination of services based on degrees obtained from a University established under an Act subsequently declared ultra vires is sustainable, and whether the protection afforded to students currently studying at the time of such declaration can be extended to those who had already passed out.
The facts of the case were that the appellants obtained their Bachelor of Library Science degrees in 2004 from the University of Technology and Science, Raipur, which was established under the Chhattisgarh Niji Kshetra Vishwavidyalaya Act, 2002. In 2005, the Hon’ble Supreme Court in Prof. Yashpal v. State of Chhattisgarh declared the 2002 Act ultra vires, leading to the dissolution of universities established thereunder. In 2010, the appellants were appointed as librarians by the State of Bihar and served for over five years. However, following a PIL and subsequent state action, their services were terminated in 2015 on the ground that their degrees were from an unrecognized institution. The Hon’ble High Court dismissed their challenges, affirming the termination.
The Hon’ble Supreme Court held that the appellants should not be deprived of the benefits of their degrees as they were not at fault, having studied in a University established under a then-valid State Act. The Court noted that in the Prof. Yashpal case, directions were specifically issued to protect the interests of students by facilitating their affiliation with other State universities. Since there was no evidence that the University was bogus or that no actual instruction was imparted, the Court found the termination illegal. Consequently, the Hon’ble Supreme Court set aside the Hon’ble High Court’s order and directed the reinstatement of the appellants with continuity of service, though without back wages.
The significance of this case lies in its interpretation of administrative fairness and its impact on the career security of bona fide students. The Hon’ble Supreme Court’s decision underscores a pivotal principle, individuals should not be penalized for the legislative incompetence of the State. By affirming that degrees obtained prior to the striking down of a statute remain valid for employment, the Court reinforces the principle that procedural and legislative changes should serve justice without causing undue hardship to innocent parties. This ruling provides a precedent for balancing the rigour of constitutional declarations with judicial pragmatism and equity.