Academic regulations should be applied in a manner that balances institutional requirements with the genuine difficulties faced by women students ensuring that motherhood does not become an obstacle to the pursuit and completion of education, the Madurai Bench of the Madras High Court has said while granting relief to an LLM student.

The court was hearing a petition filed by R. Sangeetha, a student of Government Law College, Madurai. The petitioner sought a direction to the Tamil Nadu Dr. Ambedkar Law University and Government Law College, Madurai, to consider her representation requesting permission to remit the dissertation fee, submit her LL.M. dissertation, participate in the viva voce examination and, upon successful completion thereof, obtain the certificate evidencing completion of LLM degree.

Though she had successfully completed all the theory papers, she could not submit the dissertation, which is a mandatory component of the course. She conceived in March 2024 and delivered a female child in December 2024. Due to pregnancy, childbirth and the responsibility of caring for the newborn child, she was unable to complete and submit the dissertation within the time stipulated under the regulations.

Justice Hemant Chandangoudar said the court ordinarily refrain from interfering with academic regulations unless the action complained of is arbitrary, unreasonable or results in manifest injustice.

At the same time, academic regulations cannot be applied in a manner that completely ignores exceptional circumstances, particularly those arising out of biological and social realities faced by women students.

The materials placed before the court show that the petitioner had already completed all theory examinations within the normal period. The only remaining requirement for obtaining the LLM degree was submission of the dissertation and participation in the viva voce examination. Thus, the petitioner is not seeking exemption from any academic requirement. She merely seeks an opportunity to complete the final component of the course, the court said.

A woman undergoing pregnancy and thereafter caring for a newborn child cannot be placed on the same footing as an ordinary student for the purpose of strict application of the academic timelines. Denial of an opportunity to submit the dissertation at this stage would effectively render several years of academic effort futile and result in a disproportionate hardship. Permitting the petitioner to submit the dissertation does not dilute academic standards in any manner, the court said.

The court directed the Tamil Nadu Dr. Ambedkar Law University and Government Law College, Madurai, to permit the petitioner to remit the dissertation fee, upon such payment, receive and accept the dissertation submitted by the petitioner, evaluate the dissertation and permit the petitioner to participate in the viva voce examination.

In the event of the petitioner successfully completing all the academic requirements, necessary certificate evidencing completion of the LLM degree should be awarded to the petitioner, the court directed.