The Himachal Pradesh High Court has ruled that admission to a three-year LLB course without first completing graduation is a clear violation of the Legal Education Rules, 2008, and such a candidate is not entitled to enrolment as an advocate.
A Division Bench of Justice G.S. Sandhawalia and Justice Ranjan Sharma dismissed a Letters Patent Appeal filed by Inderpal Singh, holding that his admission to the law course was invalid as he had not obtained his graduation degree when he enrolled.
“Once for want of Graduation, the admission of the appellant-writ petitioner to the LLB course was bad (being ineligible), therefore, neither any locus nor any right can be said to have accrued to the appellant… to seek enrolment as an advocate,” the Court said.
Inderpal Singh had appeared for his B.A. Third Year exams in 2014 but failed to clear one paper. Despite this, he took admission in June 2014 to a three-year LLB course at Mata Bali Sundri College of Legal Studies, Nahan. He cleared his compartment exam in March 2015, and the B.A. degree was officially awarded in July 2015—over a year after his law course had already begun.
He completed his LLB in November 2017 and later applied for enrolment with the Bar Council of Himachal Pradesh, which rejected his request on the ground of ineligibility. Singh challenged this decision through a writ petition, which was dismissed by a Single Judge, prompting the present LPA.
The Division Bench agreed with the Bar Council’s stance and the Single Judge's ruling. It observed that the petitioner had knowingly taken admission to the LLB course without possessing the required qualification at the time. The Court pointed out that Singh had even submitted an undertaking to the college acknowledging his incomplete graduation and agreeing that his admission could be cancelled if he failed to pass the pending paper.
“Diluting or easing out prescribed mandates relating to eligibility for admission to a course shall lead to educational chaos... except where expressly permitted under the Statute or Rules,” the Court warned.
Finding no exceptional circumstances or statutory allowance in the present case, the Court upheld the denial of enrolment, stating that both the Bar Council's decision and the Single Judge's order were legally sound.
Case Title: Inderpal Singh v. Himachal Pradesh University & Others
Case No.: LPA No. 295 of 2024
Date of Judgment: July 24, 2025
For the Appellant: Mr. Ajay Sharma, Senior Advocate with Mr. Atharv Sharma
For HP University: Mr. Nitin Thakur
For Bar Council & College: Mr. Arsh Chauhan
For Respondent No. 4: Mr. Sunil Mohan Goel, Senior Advocate with Mr. Raman Jumalta
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