The Himachal Pradesh High Court has held that a para-veterinary qualification obtained from a university established by law cannot be denied recognition merely because the university is not separately recognised by the State Government or registered with the Himachal Pradesh Para Veterinary Council.

The Court further held that Rule 14 of the Himachal Pradesh Para Veterinary Council Rules, 2011, to the extent it imposed such additional requirements, was in conflict with the parent Himachal Pradesh Para Veterinary Council Act, 2010 and was therefore liable to be struck down.

A Division Bench of Justice Vivek Singh Thakur and Justice Ranjan Sharma remarked that: “Rule 14 of the HPPVC Rules, 2011, to the extent it provides that institutions/Universities imparting training shall have to be registered with the State Council, as well as providing that only Universities recognized by the State Government shall be eligible for registration in the State Council, is in direct conflict with the provisions of the HPPVC Act, 2010.” 

Background:

The petitioner, a bona fide resident of Himachal Pradesh, had completed a Diploma in Veterinary Science and Animal Health Technology from the College of Veterinary Science, Rampura Phul, Punjab, a constituent college of Guru Angad Dev Veterinary and Animal Sciences University (GADVAS University), Ludhiana.

After completing the diploma, she applied for registration with the Himachal Pradesh Para Veterinary Council. Her application was rejected on the ground that the diploma was not recognised by the Himachal Pradesh Government and that the institution was not registered with the State Council, as required under Rule 14 of the HPPVC Rules, 2011.

Aggrieved, the petitioner approached the High Court under Article 226 of the Constitution.

The Court held that GADVAS University, being a university established by law, falls within the definition of a recognised institution under Section 2(j) of the HPPVC Act, 2010. Therefore, its para-veterinary qualification did not require separate recognition by the Himachal Pradesh Government. 

The Court rejected the respondents' contention that the university was required to be recognised by the State Government or registered with the State Council. It held that Rule 14 could not impose conditions beyond those prescribed by the parent Act. 

The Court held that the portion of Rule 14 requiring universities imparting para-veterinary training to be registered with the State Council and recognised by the State Government was in direct conflict with the HPPVC Act, 2010 and was therefore ultra vires. 

Consequently, the Court quashed the impugned portion of Rule 14 and the rejection communication dated July 28, 2025, and directed the State Council to register the petitioner within one week, subject to completion of other formalities. 

Case Name: Riya Sharma v/s State of H.P. & Ors.

Case No.: CWP No.14874 of 2026

Date of Decision: 15.07.2026

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