Dr. Priyambada Sharma vs. Board of Governors in Supersession of Medical Council of India
Citation: 2025 INSC 130; Review Petition (Civil) Nos. [various] of 2022
Bench: Justice Sanjay Kumar
Background
This case arose from the contentious issue of postgraduate medical admissions for the academic year 2019–20. Dr. Priyambada Sharma and other students, having failed to secure seats in the final round of counseling by the cutoff date of May 31, 2019, approached the High Court under Article 226. They sought to be considered for admission against seats that remained vacant after the official counseling process concluded. The High Court, through interim and final orders, directed the Board of Governors in Supersession of the Medical Council of India (MCI) to grant provisional admissions to these students, regularizing their status as postgraduate medical students despite the cutoff date and merit principles.
Supreme Court’s Analysis
Merit and Cutoff Dates:
The Supreme Court emphasized that the National Medical Commission (formerly MCI) and its regulations, as well as Supreme Court precedents, strictly prohibit admissions to postgraduate medical courses after the notified cutoff date (May 31). The rationale is to maintain uniformity, discipline, and fairness in medical education, ensuring that no student gains an unfair advantage by circumventing the established process.
Vacant Seats and Judicial Intervention:
The Court noted that, despite the counseling process being over, approximately 153 state quota seats remained vacant. However, it held that allowing admissions beyond the cutoff date—even to fill vacant seats—would undermine the sanctity of the process and the principle of merit. The Supreme Court criticized the High Court’s orders for regularizing admissions granted in violation of the cutoff and for disregarding merit.
Status of Dr. Priyambada Sharma:
The Court observed that Dr. Priyambada Sharma had not continued her studies since September 2019, even as some other similarly placed students were allowed to continue by their respective universities. The Supreme Court clarified that the interim and final orders of the High Court, which had regularized such admissions, were stayed and ultimately set aside.
No Legal Right to Late Admission:
The Supreme Court held that no legal right accrues to students for admission after the cutoff date, even if seats remain vacant. The Court reaffirmed that judicial orders cannot override statutory regulations and policy decisions made in the interest of maintaining standards in medical education.
Decision
The Supreme Court allowed the appeals of the Board of Governors, set aside the High Court’s orders granting and regularizing late admissions, and held that students—including Dr. Priyambada Sharma—who were admitted after the cutoff date were not entitled to continue or complete their postgraduate courses.
Significance
This judgment reinforces the inviolability of statutory deadlines and the principle of merit in medical admissions. It sends a clear message that judicial intervention cannot be used to bypass regulatory frameworks, ensuring fairness and discipline in the highly competitive field of medical education.
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