Court Rules Chancellor Exclusive Authority to Annul University Proceedings, Directs Reinstatement of Selected Candidates in Physics and Botany; Rejects State Govt. Approval Requirement for Recruitment Results
In a landmark judgment delivered on April 9, 2026, the Manipur High Court in a batch of writ petitions concerning the recruitment of Assistant Professors at Dhanamanjuri University (DMU) has held that the Syndicate, the University's principal executive body, does not possess the authority to annul its earlier decisions or the recommendations of the Selection Committee when multiple candidates are recommended. The power to annul such proceedings rests exclusively with the Chancellor, who is the Governor of Manipur, under Section 12(8) of the Dhanamanjuri University Act, 2017.
The dispute arose from the appointment process initiated in 2020 for 88 Assistant Professor posts across 22 subjects. After completion of interviews by the Selection Committee, the University’s Syndicate approved the list of 83 selected candidates (excluding Zoology) and declared results through a notification dated February 29, 2024. However, an emergency Syndicate meeting convened on July 18, 2024, following the appointment of a new Vice-Chancellor, declared the earlier notification null and void. The Syndicate cited the absence of State Government approval per Office Memoranda (OMs) issued by the Department of Personnel, Government of Manipur, and alleged that the tabulation sheets for Physics and Botany subjects were blank, indicating no proper assessment of candidates.
Consequently, the University issued fresh notifications excluding selected candidates in Physics and Botany and scheduled new interviews for these subjects. Selected candidates challenged the validity of these actions, claiming they had already been validly appointed based on the earlier notification. They argued that the Syndicate’s cancellation was arbitrary, violated their rights under Article 14 of the Indian Constitution, and that State Government approval was not required under the DMU Act for recruitment decisions.
The Court thoroughly analyzed the provisions of the DMU Act, 2017, particularly focusing on Sections 10, 12, 13, 14, 17, 20, and 30, along with various Statutes appended in the Second Schedule dealing with the powers of the Vice-Chancellor, Registrar, Syndicate, and Selection Committee. The Court emphasized that:
1. The Syndicate is the competent authority to appoint teaching staff on the recommendation of the Selection Committee.
2. The Syndicate may reject a single-person recommendation of the Selection Committee for appointment but cannot annul recommendations involving multiple candidates; such annulment requires referral to and order by the Chancellor.
3. The Vice-Chancellor has exclusive authority to convene Syndicate meetings, including emergency ones, without requiring permission from the Registrar.
4. The University, as a statutory body, is not bound to obtain prior State Government approval for recruitment and declaration of results unless a "difficulty" arises under Section 30 of the Act, which was not demonstrated here.
5. The alleged blank tabulation sheets for Physics and Botany were not contemporaneously raised as an issue during the initial recruitment process or at the time of declaration of results by the former Vice-Chancellor. Subject experts affirmed that candidates were assessed and marked appropriately.
6. The Syndicate’s cancellation of the earlier notification and fresh interviews for Physics and Botany were held to be illegal and without jurisdiction.
The Court accordingly set aside the Syndicate's resolution and the notifications dated July 18 and 19, 2024, to the extent they annulled appointments in Physics and Botany. It directed the University to reinstate the selected candidates from the February 29 notification and issue their appointment letters forthwith. The Court permitted the University to conduct fresh interviews only for additional posts created beyond the original advertised vacancies, clarifying that new appointees would be junior in seniority to those already appointed.
Writ petitions filed by unsuccessful candidates seeking fresh interviews for advertised posts were closed as infructuous or dismissed as not maintainable where the underlying notification had already been superseded.
The judgment is significant as it safeguards the sanctity of the university's autonomous recruitment process under the DMU Act and restricts administrative overreach by the Syndicate in annulling valid selections. It clarifies the limited role of the State Government in university recruitment and underscores the Chancellor’s exclusive power to annul university proceedings, ensuring due process and institutional autonomy.
Bottom line:-
Dhanamanjuri University Act, 2017 - Appointment of Assistant Professors - Syndicate cannot annul recommendations of Selection Committee or its earlier decisions; such power rests exclusively with the Chancellor under Section 12(8) of the Act.
Statutory provision(s):
Dhanamanjuri University Act, 2017 Sections 2(2), 2(3), 4(4), 10(f), 10(g), 12(1), 12(8), 13(3), 14(1), 17(1), 20(b), 30; Second Schedule Statutes 3(iii), 3(v), 7(iv), 12(i), 13(i), 26(ix), 27(i), 27(ii), 27(iv), 27(v)
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This report comprehensively covers the Court's findings and directions, providing clarity on the legal and procedural aspects of the appointment controversy at Dhanamanjuri University.
Dr. Thongram Kamala Devi v. Dhanamanjuri University, (Manipur) : Law Finder Doc id # 2880203
