-Palak Jhalani & Rashi Jeph* In 2018, the University Grants Commission (“UGC”) instructed central universities without relevant statutes, ordinances, and regulations to adopt the Central Civil Services (Conduct) Rules, 1964 (“CCS Rules”) for service matters. In February 2021, a draft was circulated by the board of the Indian Institute of Management, Calcutta, which contained the proposed code of conduct (“IIM-C Draft Rules”) that are heavily reliant on the CCS Rules, for the