Introduction

The Patna High Court has granted relief to three students pursuing the Bachelor of Ayurvedic Medicine and Surgery (BAMS) course, directing the Aryabhatta Knowledge University (AKU) to permit them to appear in the ongoing 3rd Professional Examination, notwithstanding their pending backlog from the previous academic year.

The petitioners — Ravi Ranjan, Shruti Kumari, and Baby Kumari — are enrolled in the BAMS programme under the aegis of AKU. Having been unsuccessful in certain subjects of their 2nd year (2nd Professional) examination, they were afforded the opportunity to appear in a first supplementary examination conducted by the university, commencing on 12.05.2026, the result of which was declared on 20.08.2026. Despite their efforts, each of the petitioners remained unable to clear one subject. In the interim, the university proceeded to notify the schedule for the 3rd Professional Examination, commencing 25.08.2026 and continuing until 21.09.2026, thereby precluding the petitioners from continuing their academic progression.

Appearing on behalf of the petitioners, Senior Advocate Mr. P.N. Shahi, along with Advocates Ms. Shubhangi Pandey and Mr. Anand Vardhan, placed reliance upon the National Commission for Indian System of Medicine Act, 2020, and the accompanying Notification dated 16.02.2022. It was submitted that Clause 11(b)(ii) of the said Notification expressly permits students who have failed in one or two subjects of the 2nd Professional Examination to be allowed to keep the term of the 3rd (final) Professional Session. It was further contended that the delay in conducting the second supplementary examination, itself mandated under Clause 11(b)(i) of the Notification, was attributable to the respondent authorities and had caused serious and irreversible prejudice to the petitioners, who stood to lose an entire academic year through no fault of their own.

Counsel appearing for the University and the State did not dispute the underlying facts but submitted that, with the 3rd Professional Examination having already commenced, the University faced certain practical difficulties in accommodating the petitioners' claim. However, upon a query from the Court, the University's counsel obtained instructions from the Examination Controller and conveyed that no objection would be raised, provided the Principals of the two concerned colleges were agreeable to holding the examination for the petitioners.

Having considered the submissions advanced by counsel for the respective parties, and upon perusal of the relevant statutory provisions and the Notification dated 16.02.2022, particularly Clause 11(b)(i) and (ii), Justice Harish Kumar held that the petitioners were entitled to be permitted to continue into the 3rd (final) Professional Session, more so since the delay in conducting the second supplementary examination was occasioned by the concerned college and not attributable to the petitioners.

The Court accordingly directed the Examination Controller of AKU, together with the Principals of the two respondent colleges, to allow the petitioners, along with all other similarly situated students, to appear in the ongoing 3rd Professional Examination. It was further clarified that any examination missed by the petitioners or similarly placed students during this period shall be conducted afresh as a special examination upon conclusion of the 3rd Professional Examination. The Court also clarified that the present order would not preclude the University from conducting the second supplementary examination for other unsuccessful students of the 2nd Professional Examination within a reasonable period. The writ petition was accordingly allowed.

Case Title: Ravi Ranjan & Ors. Vs. The State of Bihar & Ors.

Civil Writ Jurisdiction Case No. 13193 of 2026