Case Summary: St. Stephen's College vs The University of Delhi (1991)
Citation Stats: (1991) 12 SC CK 0022 | AIR 1992 SC 1630 | (1991) 4 JT 548 | (1991) 2 SCALE 1217 | (1992) 1 SCC 558 | (1991) 3 SCR 121 Supp
Court: Supreme Court of India
Bench: Full Bench – Yogeshwar Dayal, J; M. M. Kasliwal, J; M. Fathima Beevi, J; K. Jagannatha Shetty, J; M.H. Kania, J
Date of Decision: 06-12-1991
Final Decision: Overruled
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=274152
Facts of the Case
St. Stephen's College, affiliated to Delhi University and receiving state aid, had an independent admission programme prioritising Christian students. Delhi University issued circulars in 1980 prescribing uniform admission deadlines and merit-based criteria. The College, citing minority institution status under Article 30, refused to fully comply, maintaining interviews as part of its process and an earlier application deadline.
Law Points Raised
1. Whether minority-aided institutions can frame independent admission policies.
2. Extent of State/University control over admissions in such institutions.
3. Whether giving preference to students of a particular religion violates Articles 14, 15(4), 16(1), and 29(2) of the Constitution.
Acts / Provisions / Articles Referred
• Constitution of India – Articles 14, 15(4), 16(1), 16(4), 23, 28(3), 29(1), 29(2), 30, 30(1), 30(2), 133(1)(a), 226, 337.
• Delhi University Act, 1922 – Sections 2(a), 6.
Judgements Referred
• Kerala Education Bill, 1957 (Re:), AIR 1958 SC 956
• State of Kerala vs Very Rev. Mother Provincial, AIR 1970 SC 2079
• Ahmedabad St. Xavier's College Society vs State of Gujarat, AIR 1974 SC 1389
Obiter Dicta
Minority institutions, even when aided by the State, have the right to administer their institutions, but this is subject to reasonable regulation to ensure academic standards and prevent maladministration.
Ratio Decidendi
The Court held that while minority-aided institutions have autonomy in administration under Article 30(1), such autonomy is not absolute. The State can impose reasonable regulations in the interest of fairness, transparency, and academic excellence, but cannot annihilate the core right of minorities to manage admissions.
Final Ruling
The Supreme Court upheld the right of St. Stephen's College to conduct interviews and give preference to Christian students, provided that such preference does not exceed 50% of available seats and the rest are filled on merit from the general category.
Relevant Paragraph Numbers
Paras: 28, 32, 43, 55, 59, 65, 68, 75, 82, 94.
Summary
This landmark case balanced the constitutional right of minority-aided institutions to administer admissions with the State's interest in ensuring fair and merit-based access to education. The judgment recognised limited religious preference while safeguarding merit and transparency in higher education.
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=274152