Deemed university is not a "university established by law" for Dental Council representation under the Dentists Act.

Section 3(d) of the Dentists Act confines representation to a "University established by law", meaning a university created or incorporated by a Central, Provincial or State Act. A deemed university under Section 3 of the University Grants Commission Act is treated as distinct from such a university, and the statutory fiction in the UGC Act cannot be extended to enlarge Section 3(d). On that construction, a deemed university is not entitled to send a representative to the Dental Council of India under that clause, and exclusion of a deemed university from the constituency was stated to be invalid.

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Issues: Whether a deemed university under Section 3 of the University Grants Commission Act, 1956 falls within the expression "University established by law" in Section 3(d) of the Dentists Act, 1948 and can therefore send a representative to the Dental Council of India.

Analysis: The expression used in Section 3(d) of the Dentists Act is not merely "University" but "University established by law", which denotes a university created or incorporated by a Central, Provincial or State Act. The University Grants Commission Act draws a clear distinction between a university established by law, an institution deemed to be a university under Section 3, and an institution specially empowered to confer degrees. Section 23 of the University Grants Commission Act further shows that a deemed university is not treated as a university established or incorporated by law. Applying the ordinary meaning of the statutory language and giving full effect to the legal fiction created by Section 3 of the University Grants Commission Act, the phrase in Section 3(d) cannot be expanded to include a deemed university.

Conclusion: A deemed university does not fall within the phrase "University established by law" in Section 3(d) of the Dentists Act, 1948 and is not entitled to representation under that clause.

Final Conclusion: The exclusion of the deemed university from the constituency under Section 3(d) was held invalid, and the election made on that basis was quashed.

Ratio Decidendi: The statutory phrase "University established by law" is confined to universities created or incorporated by law and cannot be enlarged by legal fiction to include a deemed university.

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