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Anmol v. Union of India

Civil Appeal · 2025 INSC 313Decided 21 Feb 2025
C.A. No.-014333-014333-2024 (arising out of SLP(C) No. 27632/2024)
Justice B.R. Gavai · Justice K.V. Viswanathan

Background

The appellant, a person with a locomotor disability (club foot, finger deformities) and a speech and language disability, together computing to a 58% disability, had an excellent academic record and secured a good rank in the NEET-UG 2024 exam under the Persons with Disabilities (PwD) category. A Disability Assessment Board at Government Medical College, Chandigarh, however, declared him ineligible for the MBBS course based purely on his quantified disability percentage, without assessing his actual functional ability, and the Punjab and Haryana High Court upheld this denial. The Supreme Court had earlier directed AIIMS to set up a fresh medical board, including a specific expert, Dr. Satendra Singh, to properly assess whether his disability would actually prevent him from pursuing medical studies.

Decision Breakdown

Five of the six AIIMS board members largely reiterated that the appellant was unsuitable for the MBBS programme, but Dr. Satendra Singh's separate, more detailed opinion found that the appellant could pursue medical studies with reasonable accommodations and assistive technology, and concluded that incompetence should not be presumed at the outset. The Supreme Court preferred Dr. Singh's individualized, functional assessment over the more generalized opinion of the other members, holding it better satisfied the legal standard set in the Court's own earlier rulings (Omkar Ramchandra Gond and Om Rathod) requiring a genuine, detailed functional assessment rather than a mechanical disability-percentage cutoff. It confirmed the admission it had already provisionally granted to the appellant at a government medical college in Sirohi, Rajasthan, set aside the High Court's contrary order, and separately directed the National Medical Commission to report on its progress in issuing revised, disability-rights-compliant admission guidelines as previously ordered.

Lesson Learnt

A person with a disability cannot be denied admission to a professional course based merely on a quantified disability percentage; authorities must conduct an individualized, functional assessment of whether the person can actually perform the course's requirements, with reasonable accommodations, before ruling them out.

Official source (sci.gov.in)View Judgment (PDF)

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