Introduction

The Supreme Court of India, on August 9, 2023, delivered its verdict in Dev Gupta v. PEC University of Technology & Others, a case centered on the legality of eligibility conditions imposed for admissions under the sports quota in professional educational institutions. The appellant, Dev Gupta, was denied admission under the 2% sports quota due to not meeting a 75% academic cutoff in his Class 12 examinations. He argued that such a condition defeated the purpose of the sports quota, which is meant to recognize sporting merit rather than academic performance. The case raised significant constitutional questions under Article 14 (Equality before Law) regarding whether imposing such conditions was arbitrary and discriminatory.

Background

Dev Gupta applied for admission to an engineering course at PEC University of Technology under the 2% sports quota. Although he met the eligibility under the Punjab State Sports Policy, his application was rejected because he had scored below 75% in his Class 12 exams. The university had independently introduced this academic cutoff, which was not part of the state policy. Gupta challenged this as unconstitutional and unfair, contending that the sports quota exists to reward athletic merit and not academic excellence. His petition was dismissed by the Punjab and Haryana High Court, prompting him to appeal before the Supreme Court.

Key Developments

• PEC University introduced a minimum 75% marks eligibility requirement for all applicants, including those under the sports quota.

• Dev Gupta’s application was rejected despite his sports achievements.

• The High Court upheld the university’s decision, after which Gupta appealed to the Supreme Court.

• The Supreme Court examined whether the university had the authority to add academic conditions not present in the Punjab State Sports Policy.

Issues

Whether imposing a 75% academic eligibility condition for admission under the sports quota by PEC University of Technology was arbitrary, discriminatory, and violative of Article 14 of the Constitution of India.

Judgment

The Supreme Court ruled in favor of Dev Gupta, holding that PEC University’s imposition of the 75% minimum marks condition for the sports quota was arbitrary and unconstitutional. The Court reasoned that the sports quota aims to promote sporting excellence, not to evaluate academic merit. It noted that the university could not unilaterally introduce conditions beyond those specified in the Punjab State Sports Policy. The Court directed the university to fill remaining sports quota seats without applying the 75% condition within two weeks but clarified that already completed admissions would remain unaffected.

Current Status

The judgment reinforced that sports quota admissions must prioritize sports performance over academic marks, aligning institutional rules with government policies. PEC University was required to adjust its admission process accordingly.

Conclusion

The Supreme Court’s decision in Dev Gupta v. PEC University of Technology upholds the spirit of substantive equality under Article 14 by ensuring that sports quota candidates are judged based on athletic, not academic, merit. The Court reaffirmed that imposing uniform academic standards on distinct categories such as sports quotas violates the principles of fairness and equality. This ruling safeguards the integrity of affirmative action and provides clarity for future admissions under special categories.