University established by law means more than degree-granting status; statutory institute lacked electoral eligibility under the Dentists Act.

The phrase "university established by law" in Section 3(d) of the Dentists Act was treated as a single legal concept, requiring a statutory university and not merely an institution empowered to confer degrees. Although the All India Institute of Medical Sciences Act, 1956 created a statutory institution with authority to award degrees and diplomas and its own governing body, that did not make AIIMS a university established by law. The University Grants Commission Act, 1956 separately recognises universities, deemed universities, and other degree-awarding institutions, confirming that degree-conferring power alone is insufficient. The text of Section 3(d) was held clear, and reading down could not extend it beyond its language.

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Issues: Whether the All India Institute of Medical Sciences could be treated as a university established by law within the meaning of Section 3(d) of the Dentists Act, 1948 so as to entitle it to elect a member to the Dental Council.

Analysis: The expression used in Section 3(d) is not merely "university" but "university established by law", and the two parts form a single legal concept. The All India Institute of Medical Sciences Act, 1956 shows that the Institute is a statutory institution empowered to confer degrees and diplomas and has its own governing body, but that does not convert it into a university established by law. The statutory scheme of the University Grants Commission Act, 1956 separately recognises universities, deemed universities, and institutions specially empowered to confer degrees, showing that an institution may lawfully grant degrees without becoming a university. The language of Section 3(d) was held to be clear, and the doctrine of reading down could not be used to extend it beyond its text.

Conclusion: The Institute was not a university established by law for the purpose of Section 3(d), and the writ petition could not be sustained.

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