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Index Medical College, Hospital and Research Centre v. The State of Madhya Pradesh & Ors.

Civil Appeal · 2021 INSC 61Decided 3 Feb 2021
Civil Appeal No. 867 of 2021
Justice L. Nageswara Rao · Justice Indira Banerjee

Background

Several private medical colleges in Madhya Pradesh challenged Rule 12(8)(a) of the Madhya Pradesh Chikitsa Shiksha Pravesh Niyam, 2018, which barred seats that fell vacant (because a candidate allotted in the "mop-up" round of counselling did not join, or resigned after joining) from being filled in the subsequent college-level counselling round. The High Court of Madhya Pradesh had dismissed their challenge and upheld the rule. The colleges appealed to the Supreme Court, arguing this forced valuable medical seats to go permanently unfilled even though they had no role in any admission malpractice.

Decision Breakdown

The Supreme Court held that while the State's objective behind Rule 12(8)(a), stopping manipulation where less meritorious candidates benefited from vacated seats, was a legitimate goal, the specific means chosen (leaving the seats vacant altogether rather than filling them) was disproportionate and had no rational nexus to that objective. The Court noted that other provisions already penalised the defaulting candidates directly (forfeiture of their deposit and disqualification from future admission), so punishing innocent colleges by blocking seats was unnecessary and excessive. Applying the constitutional test of proportionality, the Court found Rule 12(8)(a) violated Articles 14 (equality) and 19(1)(g) (right to carry on an occupation) of the Constitution, set aside the High Court's judgment, and allowed the appeals, directing the State to fill the vacant seats through college-level counselling within 7 days.

Lesson Learnt

A government regulation, even one with a genuine anti-malpractice purpose, can be struck down as unconstitutional if the method chosen is excessive and does not reasonably connect to the stated goal, especially where it penalises innocent third parties (here, colleges) rather than the actual wrongdoers.

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

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