PREM CHAND JAIN & ANR. vs R. K. CHHABRA

The Supreme Court interpreted the University Grants Commission Act, 1956, specifically Sections 2(f), 22, and 23, to clarify that the definition of 'University' does not include companies incorporated under the Companies Act, 1913. The Court held that the Act recognizes only those institutions established or incorporated under specific statutes of sovereign legislatures, thereby setting aside the convictions and fines imposed on the appellants for contravening Sections 22 and 23. The ruling emphasized the need to prevent unauthorized institutions from awarding degrees and diplomas without legislative backing.