Rajasthan High Court Orders Release of Student's Original Documents from University

Court Rules Educational Institutions Cannot Withhold Certificates for Fee Recovery; Urges Legal Means Instead

In a landmark judgment, the Rajasthan High Court, Jaipur Bench, presided over by Justice Anuroop Singhi, has directed Jaipur National University to immediately release the original documents of a former MBBS student, Eshita Gupta. The student had petitioned the court for the return of her documents, which were retained by the university as leverage for recovering unpaid fees for her remaining course duration.

The court's decision, dated December 3, 2025, emphasized that educational institutions cannot hold onto students' original certificates as a method of fee recovery, as it severely impacts the students' academic and professional futures. The judgment stated that while institutions are entitled to recover dues, it must be done through legal channels rather than by withholding essential documents.

Eshita Gupta, who had enrolled for an MBBS course at the university, withdrew due to health issues and subsequently gained admission to Pearl University, Delhi, for a Bachelor of Design in Communication Design. However, her inability to submit original documents, including her Transfer and Migration Certificates, risked her new admission. The judgment ensured that these documents would be released without delay to enable her continuation of studies.

The court referenced prior judgments from other high courts and the Supreme Court of India, reiterating that retaining certificates infringes on students' rights and that institutes must seek alternative legal remedies for fee collection. The court dismissed the university's argument that retaining documents was necessary to prevent financial losses from unoccupied seats due to student withdrawal.

The order mandates the university to release Gupta's documents by December 4, 2025, in time for her to submit them to Pearl University before her examinations commence. This decision sets a precedent for similar disputes, highlighting students' rights to their educational certificates and the limits of institutional power in fee recovery processes.

Bottom Line:

Educational institutions cannot withhold original documents of students as leverage for fee recovery; institutions may use legal remedies for fee recovery instead of retaining the original certificates.

Statutory provision(s): Islamic Academic Education v. The State of Karnataka (2003) 6 SCC 697, M. Kesavan v. Principal Cheeran College of Pharmacy, Monika v. PT. B.D. Sharma, University of Health Sciences, Sukhmanpreet Singh Cheema v. Union of India

Eshita Gupta v. Jaipur National University, (Rajasthan)(Jaipur Bench) : Law Finder Doc Id # 2818847