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Chintpurni Medical College and Hospital & Anr. v. State of Punjab & Ors.

Writ Petition (Civil) · 2018 INSC 572Decided 3 Jul 2018
Writ Petition (Civil) No. 89 of 2018
Justice S.A. Bobde · Justice L. Nageswara Rao

Background

A medical college in Punjab, found persistently deficient by the Medical Council of India across several inspections, had already been barred from fresh admissions for two academic years by the Central Government: a bar the Supreme Court had separately upheld. The State Government then went further and withdrew the college's "Essentiality Certificate" (the certificate confirming the need for the college, originally required to even open it), after the Medical Council effectively pressured the State to do so by saying it would only act if the certificate was withdrawn. The college challenged this withdrawal, arguing the State had no legal power to cancel a certificate it had already granted.

Decision Breakdown

The Supreme Court held that the State Government had acted under the Medical Council's "dictation" rather than its own independent judgment, which by itself made the withdrawal legally invalid, since a power given to one authority cannot in substance be exercised by another. More fundamentally, the Court found that neither the Indian Medical Council Act nor its Regulations gave the State any express or implied power to withdraw an Essentiality Certificate once granted, and the certificate was quasi-judicial in nature, not an "order" that could be undone via the General Clauses Act's generic power to rescind. The Court quashed the State's withdrawal order and the related conditions, while clarifying that a certificate could still be withdrawn in cases of fraud or where its basic foundation disappears.

Lesson Learnt

A government cannot withdraw a certificate or permission it has issued merely because another regulatory body wants it to, and it needs a specific legal power to cancel what it granted, acting on someone else's "dictation," or relying on a generic statutory rescission clause, is not good enough.

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

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