St. Stephen’s College vs University of Delhi is an important judgement in relation to Article 29(2) and Article 30(1) of the Indian Constitution. The validity of the admission programme of the college as well as the preference given to Christian candidates by way of providing the community with 10% reservation was challenged in the Supreme Court of India. St. Stephen’s college was founded in 1881, and upon its affiliation to University of Delhi, it became one of the first three original constituents of the University.

The University communicated a well drafted admission schedule as well as an admission process for the programmes of BA and B. Com. However, the College instead of following this schedule and process fixed by the University, fixed their own schedule and decided they’d be taking an extra round of admissions consisting of an interview.

The Delhi University Students’ Union filed a complaint and on the basis of this complaint, a letter dated 9th June 1980 was sent to the Principal of the College asking them to adhere to the schedule to which the Principal replied stating that it was too late to make any such changes. In another communication between the Vice Chancellor of the University and the Vice Chairman of the College, it was indirectly pointed out that the College would not be conforming to the circulars of the University.

At first, a writ petition was filed by a student in the High Court of Delhi as per Article 226, but was later transferred to the Supreme Court pursuant to a writ petition being filed under Article 32 of the Indian Constitution.

The major issues discussed and deliberated upon were:

• Whether or not the College is run by a minority group?
• Is the College bound by the University's circulars if it is a minority-run institution?
• Is the College allowed to set aside seats for Christians, or will this be in violation of Indian Constitution Article 29(2)?

As per Article 30(1) in The Constitution of India;

1. All minorities, whether based on religion or language, shall have the right to establish and administer educational institutions of their choice
   
   A particular minority group, namely the Christian community, founded and administered the College, which was set up as an autonomous institution. Thus, as a minority institution, it has a distinct character and cannot be held hostage to the actions of the University when adhering to such actions may threaten the status of the College as an institution for a minority community.
   
   Article 30(1) also confers the right to administer the educational institutions established for minorities, and the admission process being an important facet of the administration shall lie under the autonomous powers of the College, no matter its affiliation with the University.
   
   The University shall only be entitled to regulate the administration, but that within reason and as long as such regulation is conducive for the minority.
   As per Article 29(2) in The Constitution of India;
    
2. No citizen shall be denied admission into any educational institution maintained by the State or receiving aid out of State funds on grounds only of religion, race, caste, language or any of them

This provision exists to ensure that admission into educational institutions is not denied because of discrimination on the basis of the aforementioned grounds. The existence of this provision does NOT contradict the existence of the Article 30(1), which basically is a safeguard to protect the interests of minority communities.

The College is a minority-run institution, and the preference given to the members of the same minority community cannot be categorised as discrimination under the purview of Article 29(2). However, the State has the power to regulate such preference awarded to members of the community by regulating the intake of students. Such reserved seats cannot surpass 50% seats in one admission year, and admission to the other communities shall be awarded strictly on the basis of merit.

As a result, the Court decided that St. Stephen's College is a minority-run institution that is not bound by the University of Delhi's Circulars for matters that come under its jurisdiction because it has a distinct character and structure.

To summarise, this case aids in identifying the characteristics of a minority-based organisation, as well as recognising that such institutions have a relatively independent existence in terms of management, and can only be interfered with in order to regulate them.