LexDraft · Judgments

Shreyas Lokchand Jamdal vs. Jawahar Navodaya Vidyalaya Samiti

Supreme Court of India · 2026

Coram: Vikram Nath, Sandeep Mehta

CIVIL APPEALS @ SLP(C) NOS.26903-26904/2026 1 IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NOS. OF 2026 (Arising out of SLP (C)Nos.26903-26904 of 2026) SHREYAS LOKCHAND JAMDAL (MINOR)& ORS. …APPELLANTS VERSUS JAWAHAR NAVODAYA VIDYALAYA SAMITI & ORS. …RESPONDENTS O R D E R 1. Leave granted. 2. The appellants are aggrieved by the final order dated 10.07.2026 passed by the High Court of Judicature at Bombay, Nagpur Bench in Writ Petition No s.4123 and 4380/2026 whereby the High Court dismissed the writ petitions filed by students challenging rejection of their admission under Rural Category to Jawahar Navodaya Vidyalayas. 3. The appellants are minor children, approximately 10 years of age, and are wards of daily wage labourers, small agriculturalists and shopkeepers residing in forest-adjoining villages of Gadricholi District and Nagpur District in Maharashtra. 4. They had appeared for the Jawahar Navodaya Vidyalaya Selection Test, 2026 (for short, the test) under the rural category and had qualified for the same. Pursuant thereto, they were granted provisional admission. CIVIL APPEALS @ SLP(C) NOS.26903-26904/2026 2 5. Subsequently, their admissions were withheld solely on the ground that the Unified District Information System for Education Plus portal (UDISE portal) reflected the schools attended by the appellants as being situated in urban areas, despite the fact that areas in which their schools were located were constituted as Nagar Panchayats under Section 341-A of the Maharashtra Municipal Councils, Nagar Panchayats and Industrial Townships Act, 1965 (for short, ‘the Act’) which applies only to areas that are in transition from rural to urban area. 6. We have heard the learned counsel appearing for the parties. 7. The same question of law came up for consideration before this Court in Adarsh Dinkar Sontakke (Minor) & Ors. v. Navodaya Vidyalaya Samiti & Ors. , 2026 INSC 865 (C.A. No.009820-009821/2026), wherein this Court, vide judgment dated 30.07.2026, has held that the constitution of an area as a Nagar Panchayat does not, by itself, alter its rural character for the purposes of the Rural Quota under the test. 8. The relevant observations of the judgment are reproduced below: “47. Hence, we are of the firm view that the exposition as made by the learned Division Bench of the High Court in Arpita Santosh More (supra) and subsequently followed in Gargi Nitesh Rasse (supra) is not the correct proposition in law. The conclusions drawn in the said judgment that the mere declaration of the area in question to be a transitional area under Article 243 -Q (2) of the Constitution of India would bring the same within the category of urban areas and in turn imply that CIVIL APPEALS @ SLP(C) NOS.26903-26904/2026 3 the area no longer remains a rural area because the process of transition has begun, is neither the pragmatic view nor one that stands to reason. 48. The presumption, in our opinion, would operate in favour of treating the area in question to be rural till the final transition takes place. It is our firm opinion that until and unless the final notification declaring the area under question to be a municipality as per the header of Article 243- Q of the Constitution of India is issued, the transitional area would definitely retain its character as a rural area.” 9. By interim order dated 06.08.2026, this Court directed the respondents to forthwith admit the appellants under the Rural Quota in the institution in question. 10. In the case of the present appellants also, no notification has been issued under Section 341-D of the Act declaring the area as a small urban area. The areas, therefore, continue to retain their rural character. Further, the subsequent classification of the schools as ‘urban’ on the UDISE portal cannot retrospectively affect the appellants’ eligibility under the Rural Category for the test. 11. We have been informed that the appellants have been granted admission to the institution pursuant to the interim order dated 06.08.2026. 12. In view of the above judgment and the position of the present appellants, the interim order dated 06.08.2026 is made absolute. 13. Appeals are accordingly disposed of in terms of judgment in C.A. No.009820-009821/2026. CIVIL APPEALS @ SLP(C) NOS.26903-26904/2026 4 14. Pending application(s), if any, shall stand disposed of. ………………………………..J. [VIKRAM NATH] ………………………………..J. [SANDEEP MEHTA] NEW DELHI; SEPTEMBER 10, 2026