In a compassionate ruling balancing academic regulations with the realities of motherhood, the Madurai Bench of the Madras High Court has permitted a woman law student to pay her dissertation fee, submit her long-pending LLM dissertation and complete her degree course despite having crossed the prescribed deadline.
Justice Hemant Chandangoudar directed the Tamil Nadu Dr Ambedkar Law University and Madurai Government Law College to accept R Sangeetha's dissertation, allow her to appear for the viva voce examination and issue her degree certificate if she successfully clears all requirements.
Sangeetha had enrolled in the LLM programme during the 2019-20 academic year. After being re-admitted due to an attendance shortage, she completed all her theory examinations in 2022. However, the dissertation - the final mandatory component for obtaining the degree - remained unfinished.
The student told the court that she conceived in March 2024 and gave birth to a daughter on December 7, 2024. Pregnancy, childbirth and the demands of caring for a newborn prevented her from completing the dissertation within the period prescribed by university regulations.
The university opposed her plea, citing the "N+2" rule, under which students admitted in 2019-20 were required to complete the course within four years. It argued that there was no provision to accept a dissertation beyond the stipulated period.
But the court said academic rules cannot be enforced in a manner that ignores "exceptional circumstances, particularly those arising out of biological and social realities faced by women students".
In a strongly worded observation, the judge noted that "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".
The court also referred to the University Grants Commission's policy encouraging institutions to extend maternity and child-care benefits to women students, and observed that educational opportunities should not be denied "merely on account of pregnancy and motherhood".
Quoting principles laid down by the Allahabad High Court, Justice Chandangoudar stressed that educational institutions must act with "compassion, fairness and sensitivity" and ensure that "motherhood does not become an obstacle to the pursuit and completion of education".
The court found that Sangeetha had already cleared all theory papers and was not seeking exemption from any academic requirement. Denying her an opportunity to submit the dissertation, it said, would render years of academic effort futile and cause disproportionate hardship.
At the same time, the judge clarified that the order was being passed only because of the "peculiar facts and circumstances" of the case, including the student's pregnancy, childbirth and post-natal responsibilities. The court expressly stated that the ruling "shall not be treated as a precedent" in cases where such exceptional circumstances are not established.
