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Legal Case Shots

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Education LawSupreme Court of India

Vidhi Himmat Katariya & Ors. v. State of Gujarat & Ors.

Writ Petition (Civil) · 2019 INSC 1137Decided 4 Oct 2019
Writ Petition (Civil) No. 885 of 2019
Justice Arun Mishra · Justice M.R. Shah · Justice B.R. Gavai

Background

Several students with locomotor disabilities who had qualified NEET (UG) 2019 sought admission to MBBS courses for 2019-20 under the 5% reservation for persons with disabilities created by the Rights of Persons with Disabilities Act, 2016. After they cleared the entrance exam, but before admissions were finalised, the medical regulator amended its rules (notification dated 4.2.2019, adding "Appendix H") to require a stricter benchmark, including that both hands be intact with full strength and range of motion, to qualify for the disability quota. Medical Boards, including one at AIIMS New Delhi, examined the petitioners and found they did not meet this stricter criterion, so they were denied admission; the students challenged this before the Supreme Court, arguing the rules had been changed "midway" after they had already qualified.

Decision Breakdown

The Supreme Court held that the amended eligibility criteria (Appendix H) were notified before the petitioners actually applied for admission under the PwD quota, the relevant date for assessing eligibility is when admission is sought, not when NEET results are declared, so there was no retrospective change of rules. The Court also held it would not sit as an appellate authority over the considered opinions of expert medical bodies (the State Medical Board, Medical Appellate Board, and AIIMS Medical Board), especially where there was no allegation of mala fide, since assessing degree of disability and fitness for a medical course is a matter for medical experts, not courts. Finding no merit in the petitioners' challenge, the Court dismissed all three connected writ petitions with no order as to costs.

Lesson Learnt

Eligibility for a reserved quota is assessed as on the date of actually seeking admission, not the date of an earlier qualifying exam, and courts will generally defer to expert medical opinion on disability-related eligibility rather than substituting their own judgment, absent bad faith.

Vidhi Himmat Katariya & Ors. v. State of Gujarat & Ors. – Legal Case Shots | LegalAware