The Madras High Court has reaffirmed that disciplinary expulsion of students cannot be final without a meaningful opportunity for appellate review. In a batch of writ petitions involving four students expelled for alleged misconduct, the Court emphasized that educational institutions must balance institutional discipline with the lifelong consequences of permanent exclusion. The judgment establishes a critical procedural safeguard for students under Article 21 of the Constitution.
Background & Facts
The Dispute
The four petitioners, all undergraduate students at SRM Institute of Science and Technology, were expelled following allegations of misconduct during a campus incident. The university issued a communication dated 16.12.2025, terminating their enrollment without providing an opportunity for appeal. The students contended that the punishment was disproportionate, especially given their age, lack of prior disciplinary record, and the fact that the aggrieved parties had filed a compromise petition in the related criminal matter.
Procedural History
- The university imposed expulsion without a formal appellate mechanism being invoked.
- The students filed writ petitions under Article 226 of the Constitution seeking quashing of the expulsion order and reinstatement.
- The university defended the action as necessary to maintain institutional discipline.
- The Court noted that while the university had an internal appellate process (Stage-I and Stage-II), it had not been offered or utilized.
Relief Sought
The petitioners sought quashing of the expulsion order and reinstatement to their respective programs, arguing that the punishment violated principles of natural justice and proportionality.
The Legal Issue
The central question was whether an educational institution may impose permanent expulsion without affording students a meaningful opportunity for appellate review, and whether such action violates the principle of proportionality under Article 21.
Arguments Presented
For the Petitioner
The petitioners, represented by Mr. V. Chandrasekaran, relied on Mohini Jain v. State of Karnataka and Unni Krishnan v. State of A.P. to argue that the right to education is an integral part of the right to life under Article 21. They contended that expulsion without appellate review amounted to a deprivation of educational opportunity without due process. They further cited State of U.P. v. Mohd. Noor to assert that disciplinary action must be proportionate and not punitive beyond the nature of the offense.
For the Respondent
The university, represented by Dr. V. Venkatesan, argued that the expulsion was justified to uphold institutional integrity and deter future misconduct. They claimed that the disciplinary committee had followed internal procedures and that the severity of the incident warranted the harshest penalty. They did not dispute the existence of an appellate mechanism but asserted that it was not mandatory to invoke it before finalizing expulsion.
The Court's Analysis
The Court examined the balance between institutional authority and student rights under constitutional jurisprudence. It held that while universities have the power to enforce discipline, they cannot act as arbiters of finality without providing a recourse. The Court emphasized that permanent expulsion is not merely an administrative sanction but a life-altering consequence that demands procedural fairness.
"The entire career of the students itself should not be put to jeopardy once and for all."
The Court distinguished between punitive action and rehabilitative discipline, noting that the existence of an appellate committee - comprising the Vice Chancellor, Registrar, and Pro-Vice Chancellor - was a built-in safeguard that must be utilized. It rejected the notion that invoking appeal implies admission of guilt, stating that natural justice requires a second look before irreversible consequences are imposed.
The Court also considered the compromise petition filed by the aggrieved parties in the criminal case, indicating that the matter was not irreconcilable. It underscored that proportionality demands that the punishment fit the offense, and that suspension, probation, or community service could serve as alternatives to permanent expulsion.
The Verdict
The petitioners succeeded. The Court held that permanent expulsion without appellate review violates natural justice and proportionality under Article 21. It directed the students to immediately file appeals before the university’s appellate committee, which must reconsider the punishment in light of the students’ age, prior record, and the possibility of lesser sanctions.
What This Means For Similar Cases
Appellate Review Is Mandatory Before Permanent Expulsion
- Educational institutions must explicitly inform students of their right to appeal disciplinary actions.
- Failure to offer or allow an appeal renders expulsion procedurally invalid.
- Practitioners must now raise natural justice and proportionality as core grounds in writ petitions against expulsion.
Suspension May Suffice as Punishment
- Institutions must consider whether suspension, conditional re-admission, or community service can achieve disciplinary goals without terminating education.
- The Court’s observation that "the period of suspension itself can be treated as punishment" establishes a new benchmark for lesser sanctions.
- Legal advisors should now routinely propose alternatives to expulsion in disciplinary hearings.
No Prejudice for Appealing
- Students may file appeals without fear that their submissions will be used against them as admissions of guilt.
- Institutions cannot treat appellate submissions as confessions or weaken the student’s position based on their appeal content.
- This principle reinforces the presumption of innocence in internal disciplinary proceedings.
