State of Madhya Pradesh vs. Vijay Kumar Tiwari
Citation: 2024 INSC 25; Bench: Justice B.R. Gavai
Background
The dispute arose when postgraduate (PG) students in Ayurveda from Autonomous Ayurveda College, Madhya Pradesh, filed a writ petition claiming discrimination in stipend payments compared to their counterparts in Allopathy (modern medicine) PG courses. The petitioners argued that their duties and responsibilities during their PG training were identical to those of Allopathy students, and thus, they deserved equal stipends. The Madhya Pradesh High Court accepted this argument and directed the State to treat Ayurveda PG students at par with Allopathy PG students regarding stipends and service conditions.
Supreme Court’s Analysis
Nature of Duties:
The Supreme Court critically examined whether the duties performed by Ayurveda PG students were, in fact, the same as those performed by Allopathy PG students. The Court found that the nature of duties, clinical exposure, and educational requirements in Ayurveda and Allopathy streams were not identical. Therefore, parity in stipends and service conditions could not be presumed solely on the basis of both being PG students in medical fields.
Precedent Relied Upon:
The Court referred to State of Gujarat v. Dr. P.A. Bhatt (2023 INSC 434), which held that equivalence in service conditions or financial benefits for different streams of medical education can only be justified if there is clear evidence of identical duties and responsibilities. The Supreme Court reiterated that administrative and financial parity must be based on substantive equivalence, not mere similarity in designation or qualification.
Reversal of High Court Decision:
The Supreme Court set aside the High Court’s order, holding that the High Court erred in assuming equivalence between Ayurveda and Allopathy PG students without a detailed comparison of their respective roles and responsibilities. The Court emphasized that policy decisions regarding stipends and service conditions fall within the domain of the State and should be based on objective criteria, not judicial assumption.
Decision
The Supreme Court allowed the appeal by the State of Madhya Pradesh, overturned the High Court’s directive for parity, and upheld the State’s discretion in determining stipends and service conditions for Ayurveda and Allopathy PG students, provided such decisions are based on rational criteria and substantive differences in training and duties.
Significance
This judgment clarifies that parity in service benefits between different streams of professional education cannot be presumed and must be grounded in demonstrable equivalence of duties. It reinforces the principle that courts should not substitute their judgment for that of expert bodies or the State in matters of educational policy unless there is clear evidence of discrimination or arbitrariness.
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