Fee autonomy in unaided education prevails absent profiteering, and admitted students cannot demand mid-course parity with later batches.

An unaided educational institution may fix fees batch-wise if the structure reflects genuine administrative and academic needs and does not amount to profiteering or capitation fee. On the facts stated, the higher fee charged to earlier NRI batches was not arbitrary merely because a later batch paid less, and the challenge failed. Students who accepted admission with notice of the applicable fee terms were also bound by those terms, so they could not claim mid-course parity with later reduced fees. The High Court's direction was therefore unsustainable and the university's fee structure was upheld.

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Issues: (i) Whether the University's differential fee structure for NRI students admitted in different batches was arbitrary or unfair; (ii) whether the students were precluded by estoppel from challenging the fee fixed at the time of their admission.

Issue (i): Whether the University's differential fee structure for NRI students admitted in different batches was arbitrary or unfair.

Analysis: Fee fixation by an unaided educational institution is part of its administration and substantial autonomy must be left to it, subject to the limits that it must not indulge in profiteering or charge capitation fee. A fee structure may legitimately reflect the institution's infrastructure needs, staffing requirements, future expansion and the need to maintain a reasonable surplus. The material showed that the course was self-financing, that the University had made budgetary arrangements for the course, and that the later reduction in fee did not make the earlier higher fee unconscionable or irrational.

Conclusion: The differential fee structure was not held arbitrary or unfair, and the challenge failed.

Issue (ii): Whether the students were precluded by estoppel from challenging the fee fixed at the time of their admission.

Analysis: The students had taken admission with notice of the applicable fee structure for their batch. A later reduction in fee for a subsequent batch did not create a right to claim parity mid-course. In these circumstances, the University was entitled to insist that the conditions accepted at admission be observed, and the plea that constitutional guarantees could override the agreed fee structure was not accepted on these facts.

Conclusion: The students were estopped from claiming a reduction to match the fee fixed for later batches.

Final Conclusion: The High Court's direction was unsustainable, and the University's fee structure for the concerned batches was upheld.

Ratio Decidendi: An unaided educational institution has autonomy to fix fees for each batch, provided the fee is not capitation or profiteering, and students who accept admission under a known fee structure cannot, as a matter of right, demand mid-course parity with a later reduced fee.

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