University grace-mark rules may be prospectively amended and apply to later examinations without infringing vested rights.

The power under section 31 of the Punjab University Act extended to framing regulations on examination conditions, including the grant and quantum of grace marks. The 1970 amendment reducing grace marks was prospective because it did not state an earlier operative date, and it applied to examinations taken after the change. A student admitted before the amendment had no vested or accrued right to insist that the earlier grace-mark rule continue to govern a later examination. The amendment therefore did not amount to retrospective legislation and validly applied to the 1974 M.B.B.S. examination.

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Issues: Whether the amended university regulation reducing the basis for grant of grace marks to M.B.B.S. candidates applied retrospectively to a student who had joined the course before the amendment, and whether the university had power under the governing statute to make such a change.

Analysis: The power conferred by section 31 of the Punjab University Act enabled the Senate to make regulations relating to courses of study and the conditions to be complied with by candidates for university examinations. That power included the authority to regulate the grant of grace marks and to alter their quantum from time to time. The amendment made in 1970 did not state that it was to operate from an earlier date and was therefore prospective in character. A student who had joined the course earlier had no accrued or vested right to insist that the regulations in force on the date of admission must govern the examination taken years later. The change merely governed the conditions for passing the later examination and did not amount to retrospective legislation.

Conclusion: The amended regulation was valid and applicable to the respondent's 1974 examination, and he was not entitled to the larger grace marks available under the earlier rule.

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