Dr. Manu v. Sree Sankaracharya University of Sanskrit

May 13, 2025

2025 KER 32675
High Court of Kerala
Judge: N. Nagaresh, J.
Writ Petition (Civil) No. 24652 of 2024; May 13, 2025
Dr. Manu v. Sree Sankaracharya University of Sanskrit & Ors.

Keywords: Writ Petition, Professor Placement, Sree Sankaracharya University, Central University of Kerala, UGC 5th Regulation, Career Advancement Scheme, API Scores, Selection Grade Lecturer, Associate Professor, Service Benefits, Past Service, Government Order, High Court of Kerala, Publication Criteria, Promotion Denial

The petitioner, a Professor and Head of the Department (Hindi) at the Central University of Kerala, sought to set aside orders denying his placement as Professor with effect from 01.06.2009 and requested revision of his placement under the 5th UGC Scheme. The petitioner, with prior service at Mahatma Gandhi University and Sree Sankaracharya University of Sanskrit, was placed as Selection Grade Lecturer from 22.12.1999 and redesignated as Associate Professor from 01.01.2006. His application for Professor placement was rejected due to insufficient API scores and non-compliance with UGC Regulations, including inadequate publications in recognized journals. The High Court dismissed the writ petition, finding no illegality in the respondents’ actions, as the petitioner failed to meet the requisite criteria for promotion under the UGC 5th Regulation.

For the Petitioner (Dr. Manu):

Sri. V. Gangadharan
Sri. Joshi N. Thomas

For the Respondents:

Respondents 1 and 2 (Sree Sankaracharya University of Sanskrit and its Vice Chancellor):
- Sri. Dinesh Mathew J. Murikan
- Sri. Ramprasad Unni T.
Respondent 4 (Central University of Kerala):
- Sri. K. Ramkumar (Senior Advocate)
- Sri. Rajesh K. Raju
Respondent 5 (State of Kerala):
- Sri. Tony Augustine, Government Pleader
Respondent 6 (University Grants Commission):
- Sri. S. Krishnamoorthy, Standing Counsel

Table of Contents

Facts

Dr. Manu, a 60-year-old Professor and Head of the Hindi Department at the Central University of Kerala, filed a writ petition challenging orders (Exts.P2, P4, P12) that denied his placement as Professor with effect from June 1, 2009, at Sree Sankaracharya University of Sanskrit. He sought modification of Ext.P7 to reflect this placement under the 5th UGC Scheme. Dr. Manu had prior service of 10 years and 6 months at Mahatma Gandhi University before joining Sree Sankaracharya University on July 14, 1999, as a Lecturer. He was placed as Selection Grade Lecturer from December 22, 1999, and redesignated as Associate Professor from January 1, 2006. His 2012 application for Professor placement was rejected due to insufficient API scores in research and publications, as his publications were not in approved journals. He was later promoted to Professor on November 12, 2017, after meeting requirements. Dr. Manu argued that his past service and the absence of a defined journal list entitled him to earlier placement, claiming prejudice by delayed university actions.

Issues

Whether the petitioner was entitled to placement as Professor from June 1, 2009, under the 5th UGC Scheme.
Whether the respondents’ rejection of his promotion application was illegal or prejudiced due to delayed processing or lack of a journal list.

Holding

The High Court dismissed the writ petition, finding no merit in the petitioner’s claims. The court held that the petitioner did not meet the UGC 5th Regulation requirements for Professor placement in 2009, specifically lacking sufficient API scores and publications in recognized journals. The absence of a defined journal list did not automatically entitle him to promotion. The petitioner’s failure to submit a Self-Assessment Report (SAR) and required records in 2007 or 2009 further justified the denial. The court found no illegality or prejudice in the respondents’ actions.

Reasoning

The court noted that the petitioner’s prior service was considered, leading to his placement as Selection Grade Lecturer from December 22, 1999, and Associate Professor from January 1, 2006, per Government Order dated March 27, 2010. However, for Professor placement, UGC Regulations required five years as Associate Professor, a SAR, and five research publications in credible journals. The petitioner’s 2012 PBAS submission was scrutinized by the Statutory Screening Committee, which found inadequate API scores due to unrecognized publications. His delayed challenge to the 2012 rejection (Ext.R1(d)) and failure to meet eligibility criteria in 2007 or 2009 undermined his claim. The court emphasized that promotion under the Career Advancement Scheme is not automatic and requires compliance with UGC standards.

Disposition

Writ petition dismissed. No relief granted to the petitioner.

API Scores, Associate Professor, Career Advancement Scheme, Central University of Kerala, Government Order, High Court of Kerala, Past Service, Professor Placement, Promotion Denial, Publication Criteria, Selection Grade Lecturer, Service Benefits, Sree Sankaracharya University, UGC 5th Regulation, Writ Petition

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