Chairman, Odisha Joint Entrance Examination v. Jasobanta Nayak & Others
Background
A candidate sought admission to an engineering course under the physically-handicapped quota in the Odisha Joint Entrance Examination 2012, relying on a certificate from a district hospital stating he had 40% visual disability. The examination prospectus, however, barred candidates from submitting their own medical certificates and required disability percentage to be certified by a specially constituted Medical Board, which had assessed him at only 20% disability. The Orissa High Court nonetheless relied on the hospital's 40% certificate and directed his consideration under the quota.
Decision Breakdown
The Supreme Court held that the High Court's finding, that candidates were required to produce a physically-handicapped certificate, was factually contrary to the prospectus, which expressly prohibited this. The Court emphasized that the percentage of disability must be determined exclusively by the Medical Board constituted under the prospectus's own rules, and that a court cannot itself assess or override a technical medical determination made by the properly constituted expert board. Since the Board had found only 20% disability (below the 40% threshold required), the High Court's interference with the selection process was unjustified. The appeals were allowed and the High Court's order was set aside.
Lesson Learnt
In disability-quota admissions governed by a specific prospectus or regulation, the disability percentage must be certified by the officially designated medical board, not by an outside hospital certificate, and courts will not substitute their own assessment for that of the properly constituted technical authority.