Supreme Court Directs Provisional Enrolment of Regular LL.B. Graduates Pending Dispute Over Prior Open/Distance Degrees
Telangana State Bar Council directed to provisionally enrol candidates; Supreme Court leaves Rule 5 controversy open for final adjudication
The Supreme Court has directed the Telangana State Bar Council to provisionally enrol certain candidates as advocates who completed their three-year LL.B. courses through the regular mode from recognised universities, although their preceding Bachelor’s degrees had been obtained through open, distance or correspondence mode.
The order was passed in STS Gladies v. Bar Council of India & Anr., Civil Appeal No. 13559 of 2025, along with connected Civil Appeal No. 13562 of 2025. The Bench comprised Justice Vikram Nath and Justice Sandeep Mehta. The Supreme Court’s own records identify both appeals as connected matters.
Dispute Before the Court
The proceedings concern the interpretation and application of Rule 5 of the Bar Council of India Rules of Legal Education, 2008.
The applicants in one of the proceedings had completed their Bachelor’s degrees from Dr. B.R. Ambedkar Open University, Hyderabad, and subsequently completed their three-year LL.B. courses through the regular mode from BCI-recognised universities. Their enrolment was withheld because of the mode in which their preceding Bachelor’s qualifications had been obtained.
In the connected matter, Kevin Sukirthy had obtained his B.Com. degree through distance mode from Madurai Kamaraj University and subsequently completed a three-year regular LL.B. from Marwadi Siksha Samithi Law College, affiliated to Osmania University. His enrolment application before the Telangana State Bar Council had not been accepted.
Supreme Court: Merits of Rule 5 Not Decided Yet
The Supreme Court specifically clarified that, at this stage, it was not entering into the merits of the controversy concerning interpretation of Rule 5.
The underlying question will be considered at the final hearing of the Civil Appeals.
The Court noted that the concerned candidates had completed their three-year LL.B. courses through regular mode from recognised universities, while the impediment to enrolment arose from the nature or mode of their earlier educational qualifications.
Why Provisional Enrolment Was Ordered
The Court observed that continued denial of enrolment during the pendency of the appeals would cause avoidable prejudice to the persons concerned and prevent them from entering the legal profession despite having completed their regular law degrees.
At the same time, the Court considered that their interests could be protected without prejudicing the final adjudication by making the enrolment provisional.
Directions to Telangana State Bar Council
The Supreme Court accordingly directed the Telangana State Bar Council to provisionally enrol:
- the applicants in I.A. No. 246673 of 2026 in Civil Appeal No. 13559 of 2025; and
- the appellant in Civil Appeal No. 13562 of 2025.
The enrolment is subject to verification of educational and other requisite documents and fulfilment of applicable requirements. It will also remain subject to the final outcome of the respective Civil Appeals.
Important: This Is Not a Final Declaration of Eligibility
A significant aspect of the order is the Court’s express clarification that provisional enrolment does not create any equity in favour of the persons concerned and that they will remain bound by the final decision in the respective appeals.
Therefore, the order should not be understood as a final Supreme Court ruling that every candidate holding a Bachelor’s degree through open or distance education is automatically eligible for enrolment as an advocate.
The final interpretation of Rule 5 remains pending.
Interim protection without prejudging the substantive question
The Supreme Court has adopted an interim course that protects the affected candidates from continued professional prejudice while preserving the substantive legal question for final adjudication.
Regular three-year LL.B. from a recognised university → provisional enrolment permitted in the present cases.
Whether the preceding open/distance/correspondence qualification satisfies Rule 5 → remains pending for final determination.
The Civil Appeals will be listed for hearing in due course.
Case Note
Primary Document
Supreme Court Order dated 09 September 2026
STS Gladies v. Bar Council of India & Anr.
Civil Appeal No. 13559 of 2025 with connected Civil Appeal No. 13562 of 2025
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