The Bar Council of India (BCI) informed the Delhi High Court on November 18, 2025 that AIBE XXI will be held in June 2026, and that the qualifying exam for Indian nationals holding foreign law degrees will be conducted between December 15 and December 20, 2025.
Justice Sachin Datta closed the petition in Saanil Patnayak v. Bar Council of India & Anr. the same day, satisfied with BCI’s on-record commitments, according to Bar & Bench.
Background: How We Got Here
The petitioner, Saanil Patnayak, is an Indian national who obtained his law degree from Brunel University of London. He subsequently completed the BCI-mandated two-year bridge course at the India International University of Legal Education and Research (IIULER) in Goa.
Despite completing that bridge course, BCI rules require such candidates to separately clear a BCI-conducted qualifying exam and then the All India Bar Examination (AIBE) before they can practise law in India. Patnayak’s petition directly challenged this dual-exam requirement.
- The petition argued that the dual-exam structure “destroys the very logic of the Bridge Course,” as stated in the petition itself and reported by Bar & Bench.
- Patnayak also asked the court to allow him to appear for AIBE XX — scheduled for November 30, 2025 — without first sitting the qualifying exam. BCI’s counsel opposed this, stating: “AIBE is for candidates enrolled as an advocate in India,” per LawChakra.
- The same legal question had previously been examined by the Delhi High Court in Mehak Oberoi v. Bar Council of India & Ors. and by the Karnataka High Court, with a Division Bench challenge reportedly still pending.
At a prior hearing on November 13, 2025, Justice Sachin Datta had sharply questioned BCI’s sequencing, as reported by Bar & Bench.
The court asked BCI: “You have created this problem; you only find a solution. You should have conducted the qualifying exam before then, this will waste a year. Why did you not schedule the qualifying exam before?”
The Ruling — Key Findings
On November 18, 2025, BCI placed its exam schedule on record before Justice Sachin Datta. The qualifying exam for Indian nationals with foreign law degrees was confirmed for December 15–20, 2025, with AIBE XXI to follow in June 2026, according to Bar & Bench.
BCI also gave a critical assurance recorded by the court: “It is further informed that upon provisional registration with the State Bar Council, the petitioner and the other similarly situated students/persons will have a period of 2 years to clear AIBE. In the intervening period, they would not be precluded from commencing their legal practice.”
With these assurances on record, Justice Sachin Datta closed the petition. The ruling means Patnayak and similarly placed candidates can begin provisional legal practice while working toward AIBE clearance, as reported by Bar & Bench and Careers360.
Separately, the Supreme Court dismissed a parallel petition filed by Patnayak on or around November 28–29, 2025. A bench of Justices Vikram Nath and Sandeep Mehta disposed of the matter after being informed that Patnayak had already approached the Delhi High Court for the same relief, per Bar & Bench and Tribune India.
Reactions & What’s Next
The petition’s core argument — that the dual-exam requirement negates the entire purpose of BCI’s own bridge course — remains unresolved as a matter of law. The broader question is still live before a Division Bench, as noted by Bar & Bench.
For now, the immediate practical relief for foreign law degree holders is clear: the qualifying exam window opens December 15, 2025, and those who clear it will be eligible to sit AIBE XXI in June 2026.
BCI’s confirmation that provisional enrollees will not be barred from practice during the two-year AIBE window is a significant on-record concession that may inform future litigation on this issue.
The Supreme Court’s swift disposal — directing Patnayak back to the High Court — underscores that the Delhi High Court remains the primary forum for challenges to BCI’s foreign-degree rules at this stage.
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When is AIBE XXI scheduled to be held?
The Bar Council of India informed the Delhi High Court that AIBE XXI will be held in June 2026, according to Bar & Bench. It is described as a bi-annual examination.
When is the qualifying exam for Indian nationals with foreign law degrees?
BCI confirmed before Justice Sachin Datta that the qualifying exam for Indian nationals holding foreign law degrees will be conducted from December 15 to December 20, 2025, as reported by Bar & Bench.
Can foreign law degree holders practise in India while waiting to clear AIBE?
Yes. BCI stated on record before the Delhi High Court that upon provisional registration with the State Bar Council, such candidates will have two years to clear AIBE and will not be prevented from commencing legal practice in the interim, per Bar & Bench.
Who is the petitioner and which court did he approach?
The petitioner is Saanil Patnayak, a law graduate from Brunel University of London who completed the BCI bridge course at IIULER, Goa. He filed a petition before the Delhi High Court challenging BCI’s dual-exam rule, which was closed by Justice Sachin Datta on November 18, 2025, according to Bar & Bench and LawChakra.
Disclaimer
Disclaimer: This article is for general information only and does not constitute legal advice. Laws may change or vary by case — consult a qualified lawyer before acting. The Courtroom is not liable for any reliance on this content.
