Pregnancy, motherhood shouldn't deprive women of education: Madras HC grants relief to LL.M. student

The Madurai Bench of the Madras High Court recently held that academic regulations cannot be applied in a manner that ignores the biological and social realities faced by women students, particularly in cases involving pregnancy and motherhood. [Sangeetha v. Registrar]

Justice Hemant Chandangoudar made the observation while granting relief to an LL.M. student of Madurai Government Law College who was denied permission to submit her dissertation after the expiry of the time prescribed under the “N+2” rule. It held,

"The underlying principle is that academic regulations should be applied in a manner that balances institutional requirements with the genuine difficulties faced by women students during this period, thereby ensuring that motherhood does not become an obstacle to the pursuit and completion of education."

The petitioner, R Sangeetha, had joined the LL.M. course in the academic year 2019-20. Due to shortage of attendance, she was re-admitted in 2020-21. She completed all theory examinations in 2022 but could not submit her dissertation, which was the only remaining requirement for completing the course.

She told the Court that she conceived in March 2024 and delivered a girl child on December 7, 2024. Due to pregnancy, childbirth and the responsibility of caring for her newborn, she was unable to submit the dissertation within the stipulated period.

The University opposed the plea and said Sangeetha was governed by the “N+2” rule adopted pursuant to University Grants Commission guidelines. Under this rule, a student admitted to the LL.M. programme in 2019-20 had to complete the course within four years. The respondents argued that there was no provision to accept a dissertation beyond the prescribed period.

The Court accepted that universities have the power to prescribe academic standards and timelines. However, it said that such rules cannot be applied mechanically in cases involving exceptional circumstances. The Court held that this was not a case where the student was seeking dilution of academic standards.

“The petitioner is not seeking exemption from any academic requirement. She merely seeks an opportunity to complete the final component of the course...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 Court said.

It added,

“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 academic timelines."

Justice Chandangoudar also relied on a UGC communication dated December 14, 2021, which called upon higher educational institutions to frame norms granting maternity and child-care benefits to women students, including extension of timelines where necessary. The Court also said that educational institutions cannot adopt a rigid approach in such cases.

“They are expected to act with compassion, fairness, and sensitivity, and to provide reasonable accommodation wherever possible so that a woman student is not deprived of her educational opportunities solely on account of pregnancy, childbirth, or post-natal responsibilities."

The Court found that denial of an opportunity to submit the dissertation would render several years of academic effort futile and cause disproportionate hardship.

It, therefore, directed the University to permit Sangeetha to remit the dissertation fee offline, accept her dissertation, evaluate it and allow her to participate in the viva voce examination in June 2026.

The petitioner was represented by Advocates Niranjan S Kumar and B Balamanikandan.

The University was represented by Advocate KP Krishnadas.

Government Advocate M Mahaboob Athiff appeared for Madurai Government Law College.

[Read Judgment]