In P.A. Inamder vs. State of Maharashtra, AIR 2005 SC 3226, the Supreme Court delivered a judgment on 31.10.2002, elucidating the minority status and the issue of autonomy of educational institutions. These matters were interpreted differently by the Union of India (UOI), various state governments, and educational institutions, leading to litigation in several High Courts.

During the hearings of such litigations, the need for clarification regarding professional institutions, both minority and non-minority, was recognized. Consequently, the court formulated four questions for consideration in Islamic Academy of Education v. State of Karnataka, AIR 2003 SC 3724. In this case, most of the petitioners were unaided minority and non-minority professional institutions.

Professional education should be made accessible based on the criterion of merit and on non-exploitative terms. Educational institutions in the field of professional education have an obligation and a duty to maintain requisite standards by admitting students through a fair and transparent admission procedure and charging a reasonable fee structure.