Irfan Akbani & Ors. vs The State of Madhya Pradesh & Ors.

Not available · 2024 INSC 981Decided 4 Dec 2024
Not available
Justice B.R. Gavai · Justice K.V. Viswanathan

Background

The appellants completed their Bachelor of Dental Surgery (BDS) degrees in Karnataka, Gujarat, and Maharashtra, and then took admission to Master of Dental Surgery (MDS) courses in Madhya Pradesh. Their admissions were cancelled by the Regulatory Authority for not going through the proper counselling process and for violating an earlier Supreme Court order, a decision upheld on appeal. However, under an interim High Court order, the appellants had already completed their full three-year MDS course (2016-2019) and passed their exams by the time the High Court's Division Bench finally dismissed their case and confirmed the cancellation.

Decision Breakdown

The Supreme Court allowed the appeal and directed that the appellants' admissions be regularized and their degrees issued, despite acknowledging the irregularities in their admission process. The Court's key reasoning was one of fairness in comparison: similarly situated students who had completed their BDS within Madhya Pradesh itself (rather than other states) and had comparable admission irregularities had already had their MDS admissions regularized and kept their degrees. Since the appellants had already finished the course and cleared their exams, and India faces a shortage of dental super-specialists, invalidating their years of completed education would serve no purpose. The Court was careful to state this relief was granted only because of the case's peculiar facts and explicitly directed that it must not be treated as a precedent for future cases.

Lesson Learnt

Courts can grant relief based on genuine fairness and practical hardship even where a technical rule was breached, especially once a course of action (like completing a full degree under an interim order) has already been irreversibly carried out, but such fact-specific leniency is expressly not meant to become a general rule that others can rely on.

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