NEW DELHI: The Madras high court has allowed an LL. M. student to pay her dissertation fee and submit her dissertation years after the prescribed deadline, holding that her pregnancy and the responsibility of caring for a newborn child were valid reasons for the delay.
What was the dispute about
Sangeetha had joined the LL. M. course in the 2019–2020 academic year. Due to an attendance shortage, she wasn't allowed to appear for her exams that year and was re-admitted in 2020–2021. She went on to clear all her theory examinations in 2022. The only thing left to complete her degree was submitting her dissertation, which is a mandatory part of the course and appearing for the viva voce examination. However, she conceived in March 2024 and delivered a baby girl on December 7, 2024. Because of her pregnancy and childbirth, she could not finish and submit the dissertation within the deadline issued by the university.
In May 2026, she submitted a representation asking the university to let her pay the dissertation fee and submit her dissertation. When no action was taken on this, she approached the high court. The university opposed her plea, citing the "N+2" rule adopted under UGC guidelines, under which a student admitted in 2019–2020 was required to finish the entire course within four years, that is, by 2024. It further argued that there was no provision allowing a dissertation to be accepted beyond this period.
What did the court say
Justice Hemant Chandangoudar acknowledged that universities have the power to set academic timelines, and that courts should not ordinarily interfere with academic regulations but academic rules can't be applied so rigidly that they ignore real, exceptional situations, especially those tied to biological and social realities that women students go through, such as pregnancy and childbirth. It noted that Sangeetha wasn't seeking exemption from any academic requirement as she had already cleared all her theory papers and only needed to complete the dissertation and viva voce: "She merely seeks an opportunity to complete the final component of the course," the court said.
The court added that educational institutions must not adopt a rigid or mechanical approach in such cases, and are instead expected to act with compassion, fairness and sensitivity, so that motherhood does not become an obstacle to a woman completing her education. The Court also clarified that allowing her to submit the dissertation now would not dilute academic standards, since she would still have to be evaluated and clear the viva voce like any other student.
The petition was accordingly allowed, with the court directing the university to let Sangeetha pay her dissertation fee offline, accept and evaluate her dissertation, and allow her to appear for the viva voce examination in June 2026. If she clears these requirements, the university must issue her degree certificate.
