Dismissed¶¶93

Sri Puttaraju L R v. Karnataka State Law University

Karnataka HC22 Jan 2026WA/1275/2025

Case brief

AI extract

What is this about?

Examination malpractice; Flying Squad; micro-xerox chits; Karnataka State Law University; Malpractice Committee; fresh inquiry after remand under Ordinance framed u/S 48(1)(d) KSLU Act 2009; CCTV footage unavailable (one-month retention); no judicial merits review of fact-finding body; MCI v. Sarang (2001) 8 SCC 427 referred; punishment: debarment from next two examinations, forfeiture, Rs. 500 penalty; writ appeal dismissed with Rs. 5,000 costs to Karnataka State Legal Services Authority; RTI application for footage; BNSS S.105 video-recording direction noted in earlier order.

What did the court decide?

No relief to the appellant; appeal dismissed with costs of Rs. 5,000/- payable to the Karnataka State Legal Services Authority within two weeks; pending applications disposed of. ¶¶93

Sri Puttaraju L R Vs Karnataka State Law University — Karnataka HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

No relief to the appellant; appeal dismissed with costs of Rs. 5,000/- payable to the Karnataka State Legal Services Authority within two weeks; pending applications disposed of.

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Issue for consideration

Whether the failure to preserve/provide the CCTV (video) footage of the examination held on 12.04.2024 furnishes a ground to challenge the Malpractice Committee's fresh order. +1 more

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Court's answer

The allegation that the University or the Law College deliberately withheld the CCTV footage from the appellant is unmerited, the storage for the CCTV system having been confined to only one month.

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Ratio / Principle

It was not open for the Court to undertake a merits review of the decision of a fact-finding authority; the learned Single Judge rightly so observed, and the present appeal lacks merit.

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Key takeaways

The chits (xerox copies reduced in size to a few inches) were evidently reduced in size to conceal them, and the appellant did not controvert that the answers at page Nos. 7 and 8 of the answer booklet exactly matched the printed xerox material found with him.ratio¶¶87
The Bench expressed reservations about some of the blanket directions issued in the earlier order (CCTV, body-worn cameras, jammers, video-recording of proceedings) but expressly declined to examine them, as neither the University nor the Law College assailed those directions.obiter¶¶69

Detailed headnote1 paragraphs

Division Bench (Vibhu Bakhru, CJ and C.M. Poonacha, J) dismissed a writ appeal under Section 4 of the Karnataka High Court Act against the learned Single Judge's order dated 27.06.2025 in W.P.No.17074/2025 declining interference with the Karnataka State Law University Malpractice Committee's fresh order dated 02.06.2025. On re-inquiry pursuant to remand, the Committee found the first-year LL.B. student guilty of copying in the Legal Methods examination (12.04.2024) from thirteen reduced-size micro-xerox chits, matching answers at pages 7-8 of his answer booklet, and recommended debarment from the next two examinations, forfeiture of the tainted examination and a Rs. 500/- penalty. Held: (i) the charge of deliberate withholding of CCTV footage was unmerited, storage being limited to one month; (ii) no merits review lies of a fact-finding authority's decision, and the appellant never controverted the matching of his answers with the concealed chits. Appeal dismissed with Rs. 5,000/- costs payable to the Karnataka State Legal Services Authority within two weeks. Reservations expressed about certain blanket evidentiary directions in the earlier common order (Rahul H. M.) were left open as unassailed.

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NC: 2026:KHC:3769-DB WA No. 1275 of 2025

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HC-KAR

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU

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DATED THIS THE 22^ND DAY OF JANUARY, 2026

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PRESENT

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THE HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE

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AND

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THE HON'BLE MR. JUSTICE C.M. POONACHA

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WRIT APPEAL NO. 1275 OF 2025 (EDN-RES)

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BETWEEN:

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SRI PUTTARAJU L.R. S/O RANGASWAIAH AGED ABOUT 41 YEARS R/AT NO.99, VEGASANADRA VILLAGE KYASAMBALLI VILLAGE

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KGF - 563 120 KOLAR DISTRICT

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…APPELLANT

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(BY SRI P.N. NANJA REDDY, ADVOCATE)

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AND:

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Digitally signed by PRABHAKAR SWETHA KRISHNAN

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Location: High Court of Karnataka

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KARNATAKA STATE LAW UNIVERSITY REPTD. BY ITS REGISTRAR (EVALUATION) NAVANAGAR

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HUBALLI - 580 025

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THE PRINCIPAL

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SRI KENGAL HANUMANTHAIAH LAW COLLEGE KGF - 563 120 KOLAR DISTRICT

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…RESPONDENTS

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(BY SRI GIRISH KUMAR R., ADVOCATE FOR R-1 & R-2 IS SERVED & UNREPRESENTED)

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NC: 2026:KHC:3769-DB WA No. 1275 of 2025

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HC-KAR

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THIS WRIT APPEAL IS FILED UNDER SECTION 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER OF THE LEARNED SINGLE JUDGE MADE IN W.P. NO. 17074/2025 DATED 27/06/2025 AND ALLOW THE WRIT PETITION AS PRAYED FOR AND GRANT SUCH OTHER RELIEF/S AS THIS HON'BLE COURT DEEMS FIT TO GRANT IN THE CIRCUMSTANCES OF THE CASE INCLUDING COSTS.

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THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

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CORAM: HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE and HON'BLE MR. JUSTICE C.M. POONACHA

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ORAL JUDGMENT

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(PER: HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE)

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The appellant has filed the present appeal impugning an order dated 27.06.2025 passed by the learned Single Judge of this Court in W.P.No.17074/2025 (EDN-RES) [ impugned order ].

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The appellant, who is a student of respondent No.2 (College) had filed the said petition impugning an order dated 02.06.2025 passed by the Malpractice Committee of respondent No.1 [ the University ] recommending that the appellant shall not be allowed to take the next two available examinations, besides forfeiting his performance in the examination in which he was found to have committed the malpractice. Additionally, the Malpractice

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Committee [ the Committee ] had recommended the imposition of a penalty of `500/-. The said order was passed by the Committee after examining the oral and written submissions of the appellant as well as after reviewing the report submitted by the Squad Members and the Internal Senior Supervisor (Principal of the College) and with an expert opinion. The Committee found that the appellant was in possession of printed and handwritten chits and had copied from them, as the answers written in the answer booklet matched the contents of the chits found in the appellant's possession.

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The learned Single Judge referred to the decision of the Supreme Court in Medical Council of India v. Sarang and Others, (2001) 8 SCC 427, and held that the facts found by the Fact Finding Body are required to be accepted.

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The appellant had sought to contest the allegation that he had committed any malpractice or was caught by the Flying Squad. The appellant claimed that he had filed an application under the Right to Information Act, 2005, seeking that the CCTV footage be made available to him. Since the same was not

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provided by the University, the appellant sought to challenge the Committee's decision on merits. However, the learned Single Judge declined to entertain any such challenge on the merits of the decision of the Committee.

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Prefatory facts

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The appellant was a student of first year L.L.B. and was studying in Sri Kengal Hanumanthaiya Law College [ law college ]. The first-semester examination was scheduled for March-April 2024, and the Legal Methods examination was scheduled for 12.04.2024. The appellant was issued the examination hall ticket, and he claims that he was writing his examination when the Flying Squad entered the hall and abruptly confiscated the examination paper and the hall ticket. The appellant states that he was not allowed to write the examination. It is the appellant's case that although he had not committed any malpractice and wanted to provide an explanation, the concerned person (examiner) did not allow him any opportunity to make any submission and forced him to leave the examination hall. He also claimed that he was forced to sign some papers without reading the contents and because of such conduct, he went into depression.

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HC-KAR

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According to the University, the Flying Squad visited the hall during the examination, and the appellant was found copying from xerox microchits. Thereafter, the appellant was called upon to appear before the Committee.

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The Flying Squad submitted a report dated 12.04.2024 describing the malpractice as “copied answer from chit” and the type of malpractice as “copying from chits”. The report indicates that it was not signed by the appellant and bears a noting against his signature as “Refused to sign and run away”. The report is signed by members of the Flying Squad. The Flying Squad had seized the chits from which the appellant was found copying as well as the answer sheets. The chits in question (13 in number) were microxerox copies. The opinion of the expert was sought and the expert stated that the material was relevant the subject of the examination and the candidate had used the same for copying.

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The proceedings indicate that the alleged malpractice was found to have been committed. It was recorded that the allegations were brought to the candidate's notice, and he had

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accepted them. The relevant extract of the proceedings reads as under:

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"Candidate appeared before the committee. Allegation was brought to the notice of candidate and candidate accepted that he knows allegations leveled against him. He accepted that he had Micro Xerox and Written Material and copied from it."

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The appellant had also signed the said proceeding. Notwithstanding the same, the appellant filed a writ petition (W.P.No.104892/2024) challenging the Committee's decision. He claimed that he had been compelled to sign the said document. He claimed that he was issued a notice to appear before the Committee on 29.05.2024. He states that he appeared before the Committee on the said date. However, no enquiry was conducted. The appellant and other students were asked to sign some papers and were not allowed to review their contents. He claimed that he was surprised to receive the order dated 01.07.2024, which was handed to him on 05.07.2024, imposing the following punishment:

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"Punishment imposed. "The Candidate shall not be allowed to take next one available examination besides forfeiting his performance in the examination in which he committed malpractice". Hence candidate shall not be permitted to keep terms for the next higher Semester/Year or pursue

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NC: 2026:KHC:3769-DB WA No. 1275 of 2025

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HC-KAR

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other alternative course till the above-mentioned term of punishment is over."

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The writ petition being W.P.No.104892/2024 (EDN-EX) preferred by the appellant was allowed by a learned Single Judge by an order dated 25.01.2025 following the order dated 25.01.2025 passed in W.P.No.104890/2024 (Rahul H. M. v. Registrar (Evaluation) and another: NC: 2025: KHC-D:1451). Copy of the order is placed on record.

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Plain reading of the said order passed in W.P.No.104890/2024 indicates that the petition was allowed by the learned Single Judge. The Court had noted that several matters relating to malpractices had come before the court. It was found that the University had relied on the students' confessions in most cases. The confession was further recorded in a preformatted proceedings, which included the student's details and a brief description of the inquiry proceedings and the punishment imposed. The Court noted that the confession was not in the student's handwriting but was pre-typed, on which the student had signed or was asked to sign. The Court also noted that, since the matter related to students' future careers, it should be dealt with in

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a transparent manner and observed that the procedure followed did not inspire confidence. The issue about malpractices in examinations is a serious one, and therefore, the Court felt it necessary that certain general directions be issued. In the aforesaid context, the Court had issued various directions including that Close Circuit Television (CCTV) was required to be installed in examination halls and in the event of allegations being made, the video recording could be used as evidence. Further, the invigilators would have to be provided with high-resolution bodyworn cameras so that their movement in the examination hall or the examination centre is recorded in real time and uploaded to a server, enabling verification when allegations are made. Additionally, the Court directed that jammers be installed in the examination hall so that communication to and from the examination hall by any student does not occur via radio frequency, microwaves, or mobile phones. The Court also directed that in the event proceedings are initiated against a student on account of malpractice, notice is required to be served by way of an email and the statements of the students are also required to be video recorded and uploaded on the server on a real time

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basis, so that there is no manipulation. Additionally, it was directed that the proceedings before the Committee be video recorded to ascertain if the student had been forced to sign any document or if the same was done voluntarily. The recordings and their processing were to be done in accordance with Section 105 of the Bharatiya Nagrik Suraksha Sanhita, 2023 , or any other provisions as may be applicable. The Vice Chancellor and the Registrar of the University were directed to formulate necessary rules in this regard and make it applicable to all Colleges within its jurisdiction or affiliated to the University.

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We have reservations about some of the directions issued. However, it is not necessary for us to examine the same in this appeal. The University or the Law College have not assailed these blanket directions and have not preferred any appeal against the said directions.

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The appellant’s writ petition being W.P.No.104890/2024 was allowed. The learned Single Judge set aside the order dated 01.07.2024 and remitted the matter to the Committee to once again conduct an inquiry in accordance with the Ordinance

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governing malpractice by candidates appearing in examination and officials/Supervisory staff, punishment and procedure, under Section 48(1)(d) of the Karnataka State Law University Act, 2009.

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Pursuant to the said order, the Committee once again conducted an inquiry and issued a notice dated 04.04.2025 calling upon the appellant to appear before the Committee on 09.04.2025 at 10 a.m. He was informed of the allegation of malpractice and possession of copying material during the Odd Semester Examination for the academic year 2023-2024 at the Law College. The report of the Squad Members and the Internal Senior Supervisor (Principal of the College) was also forwarded to the appellant.

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Admittedly, the appellant appeared before the Committee and also submitted a statement in writing, as well as made oral submissions. The appellant claims that he sought the video recording of the examination hall at the material time, that is, during the examination on 12.04.2024, from 9.30 am to 12.30 pm. However, the same was not provided.

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HC-KAR

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The failure to provide the video recording is the principal ground urged on behalf of the appellant before us. The learned counsel for the appellant had focused his contentions largely on non-availability of the CCTV footage of 12.04.2024. He submitted that it was necessary for the Law College to have preserved as the same would have a bearing on the allegations made against the appellant and his defence.

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The University had sent a letter to the Law College requesting for the CCTV footage of the examination held on 12.04.2024 at 09.00 a.m. The Law College responded by a letter dated 11.10.2025 informing that the same was not available as the storage for the CCTV system was confined to only one month. However, CCTV footage of students involved in malpractice has been preserved since the last semester.

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In view of the above, the allegation that the University or the Law College has deliberately withheld the CCTV footage from the appellant is unmerited.

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It would also be relevant to consider the report produced before the Committee, which clearly states that the appellant was

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NC: 2026:KHC:3769-DB WA No. 1275 of 2025

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HC-KAR

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copying answers from chits. The expert opinion indicates that thirteen (13) printed typed material along with hand written xerox material was found with the candidate. He had used the said typed and handwritten material for copying the same. The Committee had examined the report of the squad as well as the expert opinion and found that answer written at page Nos.7 and 8 of the answer booklet matched with the chits found with the appellant as reported. Copies of the chits have also been furnished.

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It is material to note that the chits are xerox copies that are reduced in size to a few inches. It is obvious that the reduction in the size of the Xerox copies would be to conceal the same. The appellant did not controvert that the answers on page Nos. 7 and 8 exactly match the printed xerox material.

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In the given facts, the Committee had passed the impugned order recommending that the appellant shall not be allowed to take the next two available examinations and forfeit his examination in which he was found to have committed malpractice and further imposed a penalty of `500/-.

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NC: 2026:KHC:3769-DB WA No. 1275 of 2025

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HC-KAR

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In the given facts, we find no merit in the present appeal. The learned Single Judge has rightly observed that it was not open for the Court to undertake a merits review of the decision of a fact finding authority. We are also constrained to observe that the present appeal is an unjustifiable imposition on judicial time.

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In view of the above, the present appeal is dismissed with cost of `5,000/- (Rupees Five Thousand only). The same shall be paid to the Karnataka State Legal Services Authority within a period of two weeks from date.

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Pending applications stand disposed of.

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Sd/(VIBHU BAKHRU) CHIEF JUSTICE

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Sd/(C.M. POONACHA) JUDGE

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KPS List No.: 2 Sl No.: 20

Procedural history

How this case reached the court

AI extract

Order under challenge
Order dated 27.06.2025 of the learned Single Judge in W.P.No.17074/2025 (EDN-RES), by which the Single Judge declined to entertain any challenge on the merits to the Malpractice Committee's decision dated 02.06.2025¶¶33
Learned Single Judge, High Court of Karnataka · 27.06.2025
Prior proceeding
Flying Squad reported that during the Legal Methods examination of 12.04.2024 the appellant was copying from chits; 13 micro-xerox chits and answer sheets were seized and expert opinion was obtained¶¶48
Prior proceeding
Malpractice Committee proceedings recorded the candidate's acceptance of the allegation (possession of micro-xerox and written material and copying therefrom), and the appellant signed the proceedings¶¶54
Prior proceeding
Original order dated 01.07.2024 imposed punishment debarring the candidate from the next one available examination besides forfeiting his performance in the examination in which malpractice was committed¶¶59
Prior proceeding
First writ petition W.P.No.104892/2024 (EDN-EX) was allowed by a learned Single Judge by order dated 25.01.2025, following the order in W.P.No.104890/2024 (Rahul H. M.)¶¶61
Prior proceeding
By the order in W.P.No.104890/2024, the learned Single Judge set aside the order dated 01.07.2024 and remitted the matter to the Committee for a fresh inquiry in accordance with the Ordinance framed under Section 48(1)(d) of the Karnataka State Law University Act, 2009, and issued general directions (CCTV, body-worn cameras, jammers, video-recorded proceedings)¶¶70
Prior proceeding
Pursuant to remand, the Committee issued notice dated 04.04.2025 for appearance on 09.04.2025; the appellant appeared, submitted a written statement and made oral submissions, claiming he had sought the video recording of 12.04.2024 (9.30 am to 12.30 pm) which was not provided¶¶74
Prior proceeding
On a request by the University, the Law College informed by letter dated 11.10.2025 that the CCTV footage of the examination of 12.04.2024 was unavailable as storage was confined to one month¶¶80
Prior proceeding
Fresh order dated 02.06.2025 of the Malpractice Committee recommending that the appellant not be allowed to take the next two available examinations, forfeiture of the examination in which malpractice was found, and penalty of Rs. 500/-; this was the order challenged in W.P.No.17074/2025¶¶88

Sri Puttaraju L R v. Karnataka State Law University

Case brief

What is this about?

What did the court decide?

Sri Puttaraju L R v. Karnataka State Law University

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Cases cited

Statutes considered

Procedural history

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Coram

Case details

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