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In a significant judgment, the Bombay High Court has held that a three-year undergraduate law degree obtained from a foreign university cannot automatically be treated as the required “First Degree” for admission to India’s three-year LL.B. course.
The judgment was passed in Yohaan Abraham v. Chhatrapati Shivaji Maharaj University & Anr. (Writ Petition No. 4739 of 2026).
The Petition
Yohaan Abraham completed Class XII in 2019 and then went to the United Kingdom. He obtained a three-year undergraduate law degree from Queen Mary University of London and later completed the Legal Practice Course (LPC).
He returned to India and applied for admission to the three-year LL.B. course at Chhatrapati Shivaji Maharaj University.
The University gave him provisional admission, and he paid ₹10,000 towards tuition fees.
However, the University later asked him to provide documents that he could not produce.
First, it asked for an Equivalence Certificate from the University Grants Commission (UGC). Abraham explained that the UGC does not issue such certificates for professional law degrees obtained from foreign universities.
The University then changed its requirement. It asked Abraham to obtain prior confirmation from the Bar Council of India (BCI) that, after completing the three-year LL.B. course, he would be eligible to enrol as an Advocate and receive a Sanad.
Abraham made several representations to the BCI and the Bar Council of Maharashtra and Goa.
The BCI did not respond. The Maharashtra and Goa Bar Council told him that only the BCI could answer the issue.
The University then cancelled his provisional admission.
The Main Question
The Division Bench of Justice R.I. Chagla and Justice Farhan P. Dubash said that the dispute was within a “relatively narrow compass.”
The main question before the Court was:
“Whether the Petitioner’s three-year undergraduate law degree obtained from Queen Mary University of London, having been recognised, or stated to be recognised by the BCI for the purposes contemplated under the applicable regulatory framework, can also be treated as the antecedent ‘First Degree’ required for admission to the three-year LL.B. course in India.”
Three-Year LL.B. Course
The Court said that India’s three-year LL.B. course is meant to be completed after a student has obtained a Bachelor’s Degree in another subject.
It is treated as a second-stage or “Unitary Degree Course in Law”.
Students who want to study law immediately after Class XII can instead take the integrated five-year law course.
The Court said that accepting Abraham’s argument would create a problem. If a three-year undergraduate law degree obtained from a foreign university immediately after Class XII could be treated as both the “First Degree” and the law degree, it would ‘render substantially meaningless’ the distinction made by the BCI’s Rules of Legal Education, 2008.
These Rules clearly make a distinction between the earlier Bachelor’s Degree and the three-year law degree that comes after it.
Foreign Degree Recognition
The Court also said that two separate issues could not be treated as the same.
Recognition of a foreign law degree for enrolment as an Advocate under Rule 37 of the BCI Rules is different from eligibility for admission to the three-year LL.B. course under Rules 4 and 5.
The Court made it clear that recognition for one purpose does not automatically make a person eligible for the other purpose.
The Court’s Decision
After examining the Advocates Act, 1961, the Rules of Legal Education, 2008, and earlier decisions, including the Karnataka High Court’s decision in Karan Dhananjaya v. BCI and the Delhi High Court’s decision in Mehak Oberoi v. BCI, the Court rejected the petitioner’s argument.
The Court held:
“For the reasons recorded above, we hold that the Petitioner’s three-year undergraduate law degree obtained from Queen Mary University of London cannot, merely by reason of its recognition by the BCI for the purposes contemplated under the regulatory framework governing foreign law degrees, be treated as the qualifying ‘First Degree’ for admission to the three-year LL.B. course in India. The BCI Notification dated 26 August 2020 does not lead to a different conclusion.”
Bridge Course
The Court said that the Bridge Course prescribed by the BCI for recognition of foreign law degrees is meant for enrolment as an Advocate.
It is not meant for admission to the three-year LL.B. course.
Therefore, the Bridge Course cannot change the nature of Abraham’s foreign degree or make it an earlier ‘First Degree’.
LPC Qualification
The Court also considered the Legal Practice Course (LPC) completed by Abraham.
It said that the LPC is a postgraduate professional qualification and:
“cannot retrospectively convert the Petitioner’s 10+2+3 undergraduate law degree into the Indian pattern of 10+2 followed by graduation and thereafter the three-year LL.B. course.”
University’s Conduct
The Court found that the University did not follow the proper procedure.
However, it held that the University’s actions did not require the Court’s interference because the legal position was clear.
The Court therefore dismissed the petition stating:
“The Writ Petition is accordingly dismissed. There shall be no order as to costs.”
Clarification
After the judgment was pronounced, Abraham’s counsel asked the Court to clarify that the judgment should not prevent him from applying for admission to the Bridge Course and/or the Qualification Examination prescribed by the BCI for recognition of foreign law degrees.
Case Details: Yohaan Abraham v. Chhatrapati Shivaji Maharaj University & Anr.
Case Details :- Yohaan Abraham v. Chhatrapati Shivaji Maharaj University & Anr
