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Dental Council of India vs Biyani Shikshan Samiti & Anr.

Civil Appeal · 2022 INSC 419Decided 12 Apr 2022
Civil Appeal No. 2912 of 2022

Background

Biyani Shikshan Samiti applied to set up a new dental college, but its applications were rejected for not meeting requirements, including a 2012 regulation change by the Dental Council of India requiring new dental colleges to be attached to a full-fledged Medical College (rather than just a general hospital, as the older rule allowed). The Rajasthan High Court's Division Bench struck down this amended regulation as arbitrary and discriminatory, and directed the authorities to reconsider the Samiti's application.

Decision Breakdown

The Supreme Court held that the Dental Council, as an expert statutory body, was entitled to make regulations to improve teaching standards, and that courts should only interfere with such regulations if they are "manifestly arbitrary": a high bar not met here. It found the amended rule had a genuine rational purpose: attaching dental colleges to established medical colleges with full teaching faculties and clinical facilities improves training quality, and distinguishing between colleges set up before and after the change was a valid classification, not discrimination. The Court also faulted the High Court for entertaining a claim for reconsideration that had already been rejected in an earlier, separate writ petition by the same party. The appeal was allowed and the High Court's judgment set aside.

Lesson Learnt

Courts generally defer to expert regulatory bodies on technical and academic policy questions unless a rule is shown to be manifestly arbitrary; a litigant also cannot keep re-litigating the same relief by filing a fresh writ petition after an earlier one on the same point has already failed.

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

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