Board of Governors in Supersession of Medical Council of India vs. Dr. Priyambada Sharma & Others
Background
After NEET-PG 2019 counselling for postgraduate medical seats in West Bengal state-quota colleges closed on 31 May 2019, about 153 seats remained vacant. Several MBBS doctors who had appeared for NEET-PG 2019 but had not secured a seat through the regular counselling rounds approached the Calcutta High Court, which by a series of interim orders (June-July 2019) directed provisional admission of these students to the vacant seats, disregarding both the cut-off date and their rank in the merit list. A later High Court order (November 2019) made these admissions permanent on the basis that the students had already studied for six months. The Medical Council of India (now National Medical Commission) appealed to the Supreme Court, which had earlier stayed these High Court orders, though in one case the university let a student continue studying despite the stay.
Decision Breakdown
The Supreme Court held that the admission schedule fixed under the Medical Council of India's Postgraduate Medical Education Regulations, 2000, including the firm 31 May cut-off for joining, is binding and cannot be relaxed by any court or authority, as settled by a consistent line of its own precedent. It rejected the argument that vacant seats should not go to waste, noting that non-clinical seats routinely remain vacant nationwide and that permitting late, out-of-merit admissions would open the door to arbitrary exceptions. It also declined to show sympathy merely because some students had continued studying (in defiance of the Court's own stay order in one instance) or had nearly finished the course, holding that letting merit-violating admissions stand would reward illegality. All the High Court's interim and final orders granting these admissions were quashed and the appeals allowed.
Lesson Learnt
Statutory admission timelines and merit-based selection for professional medical courses are strictly enforced and cannot be bypassed by interim court orders, even where seats would otherwise go unfilled or students have already invested time studying under such an order. Courts will not reward admissions obtained outside the prescribed process, including in defiance of a stay.