The Madras High Court has upheld a decision allowing a private medical college to withhold an MBBS graduate’s completion and degree certificates after the fees paid for her education were seized by the National Investigation Agency (NIA) during a criminal investigation. The Court held that the institution could not be compelled to release the certificates when it had effectively not received valid payment for the education provided.
Background of the Case
The case arose from an appeal filed by Puja Kumari, who had completed her MBBS course and compulsory internship at Chettinad Academy of Research and Education. She sought directions for the release of her Course Completion Certificate and MBBS Degree Certificate without being required to pay the fees again.
According to the records before the Court, more than ₹1.13 crore had been paid towards her medical education. However, during an investigation, the NIA seized the entire fee amount from the college after alleging that the funds were connected to unlawful activities being examined by the agency. As a result, the college treated the fee account as unpaid and declined to issue the certificates.
A Single Judge had earlier dismissed her writ petition, leading to the present appeal before the Division Bench.
Appellant's Arguments
Counsel for the appellant argued that educational certificates cannot be retained as a form of security for financial claims. It was submitted that courts have consistently held that academic certificates are not marketable property and cannot be withheld merely to recover dues.
The appellant also maintained that she had not been accused of any wrongdoing and that no criminal proceedings had been initiated against her personally. Her counsel contended that her professional future should not suffer because of allegations involving family members.
College's Stand
The medical college argued that it had lost the entire fee amount after the NIA seized the funds. The institution submitted that it had already provided education, infrastructure, faculty support, and training to the student but had ultimately received no usable fee payment.
The college further stated that its policy required full settlement of fees before completion certificates could be issued.
Court's Observations
The Division Bench of Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan acknowledged the settled legal principle that educational certificates generally cannot be withheld to recover dues.
However, the Bench emphasized that the present case involved unusual circumstances. Chief Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan observed that the matter was intertwined with issues arising from an NIA investigation and the seizure of the fee amount.
The Court noted,
“The moment the NIA seized and appropriated the fee amount from the college, the appellant’s account with the institution legally defaulted to an unpaid status.”
The Bench further observed that the college had already expended its resources in training the student and could not be forced to bear the financial burden after losing the entire fee amount.
Decision
Dismissing the appeal, the High Court held that the college was not obligated to release the completion and degree certificates until its legitimate dues were paid through lawful means. The Bench also noted that if the appellant believed the seized funds should be restored, she could pursue appropriate remedies before the competent court.
The Court consequently affirmed the Single Judge’s order and dismissed the writ appeal without costs.
Case Details
Case Title: Puja Kumari v. Union of India and Others
Case Number: W.A. No. 2422 of 2025
Judges: Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan
Decision Date: 17 June 2026
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