Kabir Paharia v. National Medical Commission
Background
The appellant, a person with benchmark locomotor disability (missing multiple fingers on both hands and toes on one foot) belonging to the Scheduled Caste category, scored very well in NEET-UG 2024 and easily cleared the cut-off for the SC/PwBD (persons with benchmark disabilities) quota, but was denied admission to MBBS after two separate medical boards assessed him as ineligible under existing National Medical Commission norms. His writ petition and appeal were both rejected by the Delhi High Court, which upheld the medical boards' findings.
Decision Breakdown
The Supreme Court, relying on its own recent precedents (Om Rathod and Anmol) recognising that PwBD candidates are entitled to "reasonable accommodation" and assistive devices rather than blanket exclusion, directed a fresh, more rigorous functional assessment by a specially constituted AIIMS Delhi medical board. That board found the appellant could successfully perform core clinical skills (chest compressions, IV cannulation, intubation, suturing) with only a minor difficulty putting on gloves, which the Court held was not a valid ground to deny him admission. Noting that a candidate who had scored lower than the appellant had already been admitted to the same reserved seat category, the Court held the denial was arbitrary and violated Articles 14, 16 and 21, set aside the High Court's order, and directed NMC to allot the appellant a seat in the 2025-26 MBBS session without requiring him to sit NEET again, while also directing NMC to finalize revised, non-discriminatory guidelines within two months.
Lesson Learnt
A disability alone cannot be used to deny a qualified candidate admission to a professional course: authorities must individually and functionally assess what the person can actually do, and "reasonable accommodation" for persons with disabilities is a constitutional right, not a discretionary favour.