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Education LawSupreme Court of India

Medical Council of India v. Jaipur National University Institute for Medical Sciences and Research Centre

Civil Appeal · 2018 INSC 582Decided 4 Jul 2018
Civil Appeal No. 6000 of 2018
Justice Uday Umesh Lalit · Justice Deepak Gupta

Background

The Medical Council of India (MCI) recommended against renewing a medical college's permission to admit a third batch of MBBS students for 2018-19 after repeated inspections found persisting deficiencies in infrastructure and clinical facilities, and the Central Government accordingly refused renewal. The college challenged this refusal before the Rajasthan High Court, which, at an interim stage (without a full hearing, since lawyers were on strike that day), stayed the government's refusal and directed that the college be allowed to admit 150 students pending final disposal of the case. MCI appealed to the Supreme Court against this interim order.

Decision Breakdown

The Supreme Court held that it was not appropriate for the High Court to grant interim relief allowing provisional admissions while the writ petition was still pending, relying on a line of its own precedents holding that such "subject to outcome" admissions cause serious prejudice to students if the institution later loses the case. Relying on the reasoning in a companion appeal decided the same day involving similar facts, the Court found the proper course was for the High Court to hear and finally decide the matter on merits rather than permit admissions through an interim order. It accordingly set aside the Rajasthan High Court's interim order of 29.05.2018, without going into or deciding the underlying factual dispute about the college's compliance, leaving that to be decided by the High Court at the already-scheduled final hearing.

Lesson Learnt

Courts are generally reluctant to let students be provisionally admitted to a course through an interim order while the real dispute over an institution's eligibility is still pending, because unwinding such admissions later causes serious hardship to students: the preferred course is a prompt final hearing on merits rather than interim relief.

Medical Council of India v. Jaipur National University Institute for Medical Sciences and Research Centre – Legal Case Shots | LegalAware