Case Summary: P.A. Inamdar and Others vs State of Maharashtra and Others
Citation: (2005) 08 SC CK 0094 | AIR 2005 SC 3226
Case No: Civil Appeal No. 5041 of 2005 & batch matters
Date of Decision: 12 August 2005
Bench: Hon’ble Chief Justice R.C. Lahoti, and Justices Y.K. Sabharwal, Tarun Chatterjee, P.K. Balasubramanyan, G.P. Mathur, D.M. Dharmadhikari, Arun Kumar
Final Decision: Appeals Dismissed
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=292598
Law Points Raised:
1. Whether private unaided professional educational institutions are entitled to complete autonomy in administration.
2. To what extent State can regulate admissions and fee structure.
3. Whether reservations can be mandated in private unaided institutions.
4. Whether ‘education’ is a charitable activity or occupation under Article 19(1)(g).
5. Whether State can impose quotas or policies on minority and non-minority institutions alike.
Ratio Decidendi:
1. Private unaided institutions have autonomy in administration, especially in admissions and fee structures.
2. State cannot impose its reservation policy on such institutions.
3. ‘Education’ is an occupation under Article 19(1)(g); hence, subject to reasonable restrictions.
4. Admissions must be fair and transparent. A Common Entrance Test (CET) can be conducted by the institutions or an association of institutions.
5. Capitation fee is impermissible, but a reasonable surplus is allowed for growth.
Final Ruling:
The Court held that private unaided institutions (minority or non-minority) have the right to establish and administer educational institutions under Article 19(1)(g) without State interference in admission and fee structures. However, reasonable regulations to prevent profiteering and ensure transparency are permissible. Government cannot enforce reservations in such institutions.
Relevant Paragraphs:
¶1-5 (Background), ¶12-13 (Pai Foundation Reference), ¶27-28, ¶68, ¶124-135 (Key Holdings)
Summary:
This landmark ruling clarified the autonomy of private unaided professional institutions. It reaffirmed that such institutions can manage admissions and fees independently, subject to fair practices and no profiteering. The decision also overruled State-imposed reservation mandates in unaided private colleges, thereby strengthening Article 19(1)(g) rights.