Gujarat University v. Krishna Ranganath Mudholkar (1963)

Quick Summary

CASE_TITLE: Gujarat University v. Krishna Ranganath Mudholkar (1963)

PUBLISH_DATE: 25 Oct 2025 | AUTHOR_NAME: Gulzar Hashmi | LOCATION: India

The Supreme Court said Gujarat University could not force Gujarati or Hindi as the only medium of teaching or exams under the Gujarat University Act, 1949. In higher education, state rules must respect Parliament’s power under Entry 66, List I. English could be used where the Act did not give power to ban it.

Issues

• Can the University mandate Gujarati/Hindi as the sole medium of instruction and exams in affiliated colleges?
• Is such a mandate valid when viewed against Parliament’s control over higher education standards under Entry 66, List I?

Rules

• The Gujarat University Act, 1949 does not give power to impose one language as the exclusive medium.
• State control over education (Entry 11, List II — as it then stood) is subject to Parliament’s power over higher education standards (Entry 66, List I).
• Universities may recommend regional languages, but cannot enforce them as the only option without clear statutory backing.

Arguments

• No power to mandate only Gujarati/Hindi: The 1949 Act does not authorize exclusive language mandates.
• Union power prevails: State measures on higher education must respect Parliament’s domain under Entry 66, List I.
• Recommendation vs. compulsion: Regional languages may be encouraged, not forced as the sole medium.
• Appeal dismissed: High Court decision in favour of the respondents upheld.

Ratio Decidendi

Where a university statute does not grant clear authority to impose a single language as the only medium, such compulsion is invalid. In higher education, state action cannot trench upon Parliament’s Entry 66 field on standards.

Why It Matters

• Protects student choice of medium where the statute is silent.
• Draws a firm line between state policy and Union control over higher education standards.
• Guides universities to act within their legal powers, not policy preferences.

Key Takeaways

Mnemonic + 3-Step Hook

Mnemonic: “UNI-LANG? NO — CHECK ENTRY-66”

1. UNI: University must act within its Act.
2. LANG: Language can be recommended, not forced.
3. ENTRY-66: Union standards trump state policies in higher education.

IRAC Outline

Glossary

Entry 66, List I

Parliament’s power over coordination and determination of standards in higher education.

Ultra Vires

Action beyond legal power granted by the statute.

Medium of Instruction

Language used for teaching and learning in classes.

FAQs

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