The Madurai Bench of the Madras High Court has reaffirmed the importance of accommodating the unique challenges faced by women in academia, especially during pregnancy and motherhood. In a noteworthy judgment, the court emphasized that academic regulations should not disregard the biological and social realities confronting female students, thereby ensuring that educational pursuits remain accessible to them. This decision was delivered in the case of Sangeetha v. Registrar, where Justice Hemant Chandangoudar granted relief to an LL.M. student from Madurai Government Law College.
Justice Chandangoudar’s ruling came in response to a petition filed by R Sangeetha, an LL.M. student who faced obstacles in completing her dissertation due to maternity-related challenges. Sangeetha had enrolled in the LL.M. course for the 2019-20 academic year but had to take a break due to insufficient attendance, rejoining in 2020-21. After completing her theory examinations in 2022, she was unable to submit her dissertation, the final component required for her degree, due to pregnancy and subsequent childcare obligations.
The University initially resisted Sangeetha’s plea, invoking the ‘N+2’ rule as per University Grants Commission guidelines. This rule mandates that students complete their courses within a specified timeframe, which, for Sangeetha, was set at four years from her initial enrollment. The University argued that they had no provision to accept dissertation submissions beyond this period.
In its deliberation, the Court acknowledged the University’s authority to uphold academic standards and deadlines. However, it stressed that these rules should not be applied rigidly in cases of exceptional circumstances such as those experienced by Sangeetha. Justice Chandangoudar highlighted that the petitioner was not seeking a waiver of academic standards but merely an extension to fulfill the course’s requirements. He asserted that academic regulations must adapt to the extraordinary circumstances shaped by women’s biological and social realities.
The Court further elaborated that a woman managing pregnancy and the subsequent care of a newborn should not be equated with other students in terms of adhering to strict academic deadlines. Justice Chandangoudar referred to a UGC communication from December 14, 2021, urging educational institutions to develop norms granting maternity and childcare considerations, including extensions where justified.
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The judgment underscored that educational bodies are expected to exercise compassion, fairness, and sensitivity, ensuring that educational opportunities are not curtailed due to pregnancy, childbirth, or related responsibilities. The Court concluded that denying Sangeetha the chance to submit her dissertation would nullify years of academic endeavor and inflict undue hardship.
Consequently, the court directed the University to allow Sangeetha to submit her dissertation, have it evaluated, and participate in the viva voce examination scheduled for June 2026. Advocates Niranjan S Kumar and B Balamanikandan represented the petitioner, while Advocate KP Krishnadas represented the University. Government Advocate M Mahaboob Athiff appeared for Madurai Government Law College.
