Janet Jeyapaul v. SRM University (2015)

Quick Summary

This case explains a simple point: even if a body is not a “State” under Article 12, the High Court can still issue a writ under Article 226 when that body performs a public duty. A deemed university runs education for the public, so it carries public duties. Therefore, students and staff can ask the High Court to review its actions.

Issues

• Can a deemed university be treated as an authority for writs under Article 226?
• Is “public duty” the key test, even if the body is not a “State” under Article 12?

Rules

• Article 12 — Defines “State” for Part III (fundamental rights).
• Article 226 — High Courts can issue writs to “any person or authority” for enforcement of rights, including non-fundamental rights.
• Principle — Focus is on the nature of duty. If the duty is public, writs can issue.

Facts (Timeline)

Arguments

Judgment (Held)

The Supreme Court held that the phrase “any person or authority” in Article 226 is wide. It covers bodies that perform public duties. Running a university is a public function. Therefore, a writ can be issued against a deemed university under Article 226, even if it is not a “State” under Article 12.

The Court emphasized the nature of duty over the form of the body. The matter was allowed to proceed on this basis; the High Court could examine the merits.

Ratio Decidendi

1. Article 226 uses broader language than Article 12; it protects both fundamental and other legal rights.
2. When an institution performs a public duty (like education), writ jurisdiction can apply.
3. Courts will look at the function and its impact on public rights, not just ownership or label.

Why It Matters

• Students and staff get legal protection against unfair decisions of private education bodies performing public functions.
• High Courts can ensure fairness without first proving the body is a “State” under Article 12.
• Makes university processes more transparent and accountable.

Key Takeaways

• Public duty = writ possible under Article 226.
• Article 226 scope broader than Article 12.
• Education is a public function affecting public rights.

Mnemonic + 3-Step Hook

Mnemonic: “ EDU = PUBLIC = 226”

1. Identify function: Is it public (education, admissions, exams)?
2. Locate right: Which legal or fundamental right is affected?
3. Choose remedy: Move High Court under Article 226.

IRAC Outline

Issue: Can writs lie against a deemed university?

Rule: Article 226 applies to “any person or authority” performing public duty; Article 12 definition is not a limit here.

Application: The university runs public education; decisions affect rights; thus, writs can check fairness and legality.

Conclusion: Yes, writs under Article 226 can be issued against a deemed university.

Glossary

Writ

A court order to do or not do something.

Public Duty

A task that serves the public interest (like running a university).

Deemed University

An institution recognized as a university for certain purposes by law.

FAQs

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