Dr. Priyambada Sharma Etc. Etc. v. Board Of Governors In Supersession Of Medical Council Of India

Civil Appeal · 2025 INSC 130Decided 28 Jan 2025
R.P.(C) No.-001739-001746 - 2023 (in Civil Appeal Nos. 7533-7534, 7535, 7536, 7537, 7538, 7539 and 7540 of 2022)
Chief Justice · Justice Sanjay Kumar · Justice K.V. Viswanathan

Background

A group of medical students/doctors had been affected by the Supreme Court's own earlier judgment dated 17.10.2022, which had implications for degrees awarded to students who completed their studies around that time and had gone on to work as Senior Residents. They filed review petitions asking the Court to reconsider the effect of that judgment on their degrees. One petitioner, Dr. Priyambada Sharma, was in a different position. She had been prevented from continuing her studies at North Bengal Medical College, Darjeeling because of the same 2022 judgment, having enrolled back in July 2019.

Decision Breakdown

The Court allowed the review petitions to the extent that students who had already completed their studies by July 2022 and gone on to work as Senior Residents would not be stripped of their degrees, treating those degrees as legal and valid despite the earlier judgment: except for Dr. Priyambada Sharma, whose situation was different. For her specifically, since she had already studied for almost three years before being stopped, the Court permitted her to continue and complete her studies at the same college. It also imposed a consolidated cost of Rs. 5,00,000 jointly on the university and the college involved, payable to the Chief Minister's Relief Fund, West Bengal, and modified its earlier 17.10.2022 judgment accordingly.

Lesson Learnt

Courts can and will revisit the practical fallout of their own earlier rulings through review petitions where rigid enforcement would unfairly derail students' careers and years of genuine study: equity for affected individuals can be built into how a precedent is applied going forward.

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