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Issues Involved:
1. Validity of transfer of students to Chandigarh Engineering College. 2. Authority of the Principal and University in sanctioning additional seats. 3. Applicability of the doctrine of Promissory Estoppel. Summary: 1. Validity of Transfer of Students: Admissions to engineering colleges in Punjab, including affiliated private colleges, are based on the Joint Entrance Test (J.E.T.). Private colleges could fill a "Management Quota" with students meeting a minimum score requirement, although students with lower scores were often admitted. Some students sought transfers to centrally located colleges like Chandigarh Engineering College, citing security concerns. The High Court had ordered the transfer of five students to Chandigarh Engineering College, which was contested by the Chandigarh Administration and Punjab University. 2. Authority of the Principal and University in Sanctioning Additional Seats: The Punjab University Act, 1947, and its regulations govern student migration. Rules under Section 20(5) specify that migration requires valid reasons, mutual agreement between college principals, and university approval. Migration is restricted to the third and fifth semesters, and students must meet specific academic criteria. The Principal of Chandigarh Engineering College initially objected to the transfers, citing no vacancies and lower J.E.T. scores of the applicants. However, he later consented, noting the need for additional seats. The Syndicate of Punjab University approved the transfers and additional seats, but the Principal later reiterated his objections, emphasizing that only the central government, in consultation with the All India Council for Technical Education (A.I.C.T.E.), could sanction additional seats. 3. Applicability of the Doctrine of Promissory Estoppel: The High Court held that the Principal could not object after initially consenting to the transfers. However, the Supreme Court emphasized that the Principal's consent was ultra vires, as it violated statutory rules. The doctrine of Promissory Estoppel, an equitable rule, cannot override statutory provisions. The Principal's consent was not legally binding due to its substantial violation of mandatory rules designed to prevent back-door admissions. The court also noted that the respondents had not changed their position based on the Principal's consent, as they were not yet admitted to Chandigarh College. Conclusion: The Supreme Court set aside the High Court's judgment, asserting that the Principal's initial consent was ultra vires and not binding. However, considering the respondents' prolonged study at Chandigarh College and the lack of timely challenge to interim orders, the court allowed respondents 1 to 4 to continue their studies there. The court advised against passing such interim orders in similar cases. Respondent 5, who had not been admitted, was directed to return to his parent college. The appeals were allowed with no costs.
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