Central Council for Indian Medicine vs Karnataka Ayurveda Medical College
Background
Karnataka Ayurveda Medical College sought permission to run Post-Graduate Ayurveda courses. Under the 2016 Post-Graduate Ayurveda Education Regulations, colleges are required to have a Central Research Laboratory and an Animal House by 31 December of the year before the academic session for which permission is sought. Following inspections, the Union of India refused permission for the college to admit PG students for 2018-19 because these facilities were deficient, though permission was later granted for the subsequent year (2019-20) once fixed. The Karnataka High Court (Single Judge and Division Bench) ruled in the college's favour, holding that since permission was granted for the later year, that permission should also be read as covering the earlier year in which the deficiencies existed.
Decision Breakdown
The Supreme Court allowed the Central Council's appeal, holding that the High Court's approach was legally incorrect. Under Regulation 3(1)(a) of the 2016 Regulations, eligibility for a given academic year must be assessed as of 31 December of the preceding year: a college fixing its deficiencies later and getting permission for a subsequent year does not retroactively cure its ineligibility for the earlier year. The Court held that the High Court had failed to correctly apply the Supreme Court's own earlier ruling in Ayurved Shastra Seva Mandal v. Union of India, which had rejected an identical argument that later-year permission should extend backward to an earlier deficient year, noting it is for expert regulatory bodies, not courts, to judge whether an institution met the year-specific standards.
Lesson Learnt
Regulatory eligibility for professional/medical education is assessed year-by-year against a fixed cut-off date; an institution cannot claim that meeting standards in a later year automatically validates its non-compliant earlier year, and courts should be cautious about second-guessing expert regulatory findings on infrastructure standards.