Priyanka Kumari vs State of Bihar 2026 INSC 167 -Chhattisgarh Niji Kshetra Vishwavidyalaya Act
Chhattisgarh Niji Kshetra Vishwavidyalaya Act, 2002 - The Supreme Court held that librarians appointed by the State of Bihar, who had obtained B.Lib degrees from the University of Technology and Science, Raipur, under the Chhattisgarh Niji Kshetra Vishwavidyalaya Act, 2002, could not be penalised merely because that Act was later declared ultra vires in Prof. Yash Pal’s case. Noting that the university was established under a state law then in force, that the Central Government had recognised its degrees, and that there was no allegation the institution was bogus or that no education was imparted, the Court protected the validity of the appellants’ degrees and found their termination illegal. The Court set aside the High Court’s orders, directed reinstatement of the appellants with continuity of service, but denied back wages for the intervening period.
Case Info
Case Information
Case name and neutral citation:Priyanka Kumari and Ors. v. The State of Bihar and Ors., 2026 INSC 167
Coram:Justice Rajesh Bindal and Justice Vijay Bishnoi
Judgment date:18 February 2026 (Supreme Court of India, Civil Appellate Jurisdiction)
Case laws and citations referred:
- Prof. Yashpal and Anr. v. State of Chhattisgarh and Ors., (2005) 5 SCC 420
- Goan Real Estate and Construction Limited & Anr. v. Union of India & Ors., (2010) 3 SCR 1160
- Anil Bhimraj Purane v. Union of India and Others, Writ Petition No. 9039 of 2012 (Bombay High Court)
Statutes / laws referred:
- Chhattisgarh Niji Kshetra Vishwavidyalaya Act, 2002
- Provisions specifically noted as struck down: Sections 5 and 6 of the 2002 Act
- References to regulatory norms of UGC/AICTE/MCI etc. via the discussion in Prof. Yashpal (re: affiliation and recognition)
Brief Summary (three sentences)
The Supreme Court held that librarians appointed by the State of Bihar, who had obtained B.Lib degrees from the University of Technology and Science, Raipur, under the Chhattisgarh Niji Kshetra Vishwavidyalaya Act, 2002, could not be penalised merely because that Act was later declared ultra vires in Prof. Yash Pal’s case. Noting that the university was established under a state law then in force, that the Central Government had recognised its degrees, and that there was no allegation the institution was bogus or that no education was imparted, the Court protected the validity of the appellants’ degrees and found their termination illegal. The Court set aside the High Court’s orders, directed reinstatement of the appellants with continuity of service, but denied back wages for the intervening period.
