Supreme Court Allows Provisional Advocate Enrolment For 3-Year LL.B. Graduates With Open/Distance Mode Bachelor’s Degrees

The Supreme Court has permitted provisional enrolment of candidates as advocates where they completed their three-year LL.B. through the regular mode but had obtained earlier educational qualifications through open, distance or correspondence courses. The Court passed the order while considering interim applications in two connected civil appeals concerning Rule 5 of the Bar Council of India’s Rules of Legal Education, 2008.

Background

The applicants in Civil Appeal No. 13559 of 2025 had completed their Bachelor’s degrees from Dr. B.R. Ambedkar Open University, Hyderabad, before pursuing regular three-year LL.B. courses from BCI-recognised universities. Their enrolment applications had not been processed because of the mode through which their earlier degrees were obtained.

In the connected appeal, Civil Appeal No. 13562 of 2025, Kevin Sukirthy had obtained his B.Com. degree through distance mode from Madurai Kamaraj University before completing a regular LL.B. in 2020. His enrolment claim before the Telangana State Bar Council was not accepted, and the Telangana High Court had rejected his challenge on October 14, 2024.

The Bench of Justice Vikram Nath and Justice Sandeep Mehta clarified that it would not decide the interpretation of Rule 5 at the interim stage. That issue would be examined when the main appeals are finally heard.

The Court noted that the applicants had completed their three-year LL.B. courses through the regular mode from recognised universities.

"Continued denial of enrolment during the pendency of the appeals would cause avoidable prejudice to the persons concerned and prevent them from entering the legal profession notwithstanding completion of their regular law degrees."

The Supreme Court directed the Telangana State Bar Council to provisionally enrol the applicants in Civil Appeal No. 13559 of 2025 and the appellant in Civil Appeal No. 13562 of 2025 as advocates. The enrolment is subject to verification of their educational and other required documents and compliance with applicable requirements.

The Court made clear that provisional enrolment would not create any right or advantage in their favour and would remain subject to the final outcome of the respective appeals.

The interim applications were accordingly disposed of, while the civil appeals were directed to be listed for hearing in due course.