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Education LawSupreme Court of India

IQ City Foundation & Anr. v. Union of India & Ors.

Writ Petition (Civil) · 2018 INSC 101Decided 6 Feb 2018
Writ Petition (Civil) No. 502 of 2017
Chief Justice Dipak Misra · Justice Amitava Roy · Justice A.M. Khanwilkar

Background

IQ City Medical College, Burdwan (West Bengal), had been granted permission in 2013 to admit MBBS students and had received three successive renewals. Its fourth renewal application (for the 2017-18 academic year, covering admission of its 5th batch of 150 students) was rejected by the Union Health Ministry on the Medical Council of India's recommendation, citing shortfalls in teaching faculty and resident doctors. In an earlier round of the same writ petition (August 2017), the Supreme Court had found the Central Government's rejection unreasoned and sent the matter back for a fresh, reasoned decision after a further hearing.

Decision Breakdown

On the second round, the Court reviewed the Hearing Committee's post-remand findings, which recorded that the college's faculty shortfall was 15.9% and resident-doctor shortfall was 25.88%, both well above the acceptable limits, and that the college's explanations (staff being away at medical camps or exam counselling on the day of a surprise inspection) did not meet MCI's leave guidelines. Finding no perversity in this reasoning, the Court upheld the Central Government's decision not to renew permission for the 2017-18 academic year. However, it added a forward-looking direction: the college's prayer for renewal would be considered afresh for the 2018-19 academic year, with any bank guarantee already furnished treated as a deposit for that fresh inspection, making clear its ruling was confined to the 2017-18 refusal alone.

Lesson Learnt

Courts will generally defer to a regulator's factual findings on compliance (like faculty/resident staffing ratios) once those findings are reasoned and based on a fair hearing, but they can still soften the practical impact: here, by ensuring one bad inspection cycle did not permanently bar the institution from applying again the following year.

IQ City Foundation & Anr. v. Union of India & Ors. – Legal Case Shots | LegalAware