The Madras High Court has ruled that academic regulations cannot be applied rigidly to disregard the biological and social realities faced by women students during pregnancy and motherhood. The court directed Tamil Nadu Dr. Ambedkar Law University to permit an LL.M. student to submit her dissertation and appear for the viva voce examination, despite exceeding the prescribed timeline.
Case Background: Student Sought Extension Due to Pregnancy
Justice Hemant Chandangoudar passed the order on a petition filed by R Sangeetha, a student of Madurai Government Law College. She sought permission to remit the dissertation fee, submit her dissertation, and complete the remaining requirements for her LL.M. degree. According to court records, Sangeetha joined the course during the 2019-20 academic year. Due to attendance shortages, she was re-admitted in 2020-21 and completed all theory examinations in 2022. The only pending requirements were the dissertation and viva voce.
The petitioner submitted that she delivered a girl child on December 7, 2024. Due to pregnancy, childbirth, and post-natal responsibilities, she was unable to complete and submit the dissertation within the period prescribed under university regulations.
University's Opposition: N+2 Rule Under UGC Guidelines
The university opposed the plea, stating that under the “N+2” rule adopted pursuant to UGC guidelines, a student admitted in 2019-20 was required to complete the course within four years. It argued that there was no provision permitting submission of a dissertation beyond that period. However, the court rejected a strict application of the regulation.
Court's Observations: Exceptional Circumstances Must Be Considered
The court observed that “academic regulations cannot be applied in a manner that completely ignores exceptional circumstances, particularly those arising out of biological and social realities faced by women students.” The judge further held that “a woman undergoing pregnancy and thereafter caring for a newborn child cannot be placed on the same footing as an ordinary student for the purpose of strict application of academic timelines.”
UGC Guidelines on Maternity and Child-Care Benefits
Referring to UGC guidelines on maternity and child-care benefits, the court said educational institutions “cannot adopt a rigid or mechanical approach” and should provide reasonable accommodation so that women are not deprived of educational opportunities due to pregnancy or childbirth. The court emphasized that denial of relief would render years of academic effort futile and cause disproportionate hardship.
Directive to University: Accept Dissertation and Conduct Viva Voce
The court directed the university to accept the dissertation fee in offline mode, receive the dissertation, evaluate it, permit the petitioner to participate in the June 2026 viva voce examination, and issue the degree certificate if she successfully completes all academic requirements.
