ISSUE:
Whether certain provisions of the Chhattisgarh Niji Kshetra Vishwavidyalaya (Sthapana Aur Viniyaman) Adhiniyam, 2002 (the Act) is ultra vires the Constitution of India?
Whether the notifications issued by the State of Chhattisgarh establishing various private universities under the Act are valid?
Whether the functioning of these private universities would hinder the statutory duties of expert bodies like University Grants Commission (UGC), Medical Council of India, and All India Council for Technical Education?
RULE:
Doctrine of Legislative Competence: The court held that state legislatures lack the power to enact laws that infringe upon the Union's authority over coordination and determination of standards in higher education.
Doctrine of Ultra Vires: The court found the Act unconstitutional because it permitted the establishment of universities without adequate oversight, infringing on the Union’s power to set higher education standards.
Principle of Regulatory Oversight by Expert Bodies: Expert bodies like UGC must regulate standards to prevent unrecognised degrees, protecting the quality and legitimacy of education.
Territorial Limitations on State Legislatures: The state legislature could not authorize private universities to establish campuses outside the state’s territorial jurisdiction, as this exceeded state legislative powers.