Manipal University & Anr. v. Union of India & Anr.
Background
Manipal University (then Manipal Academy of Higher Education), a Deemed University running medical colleges, had for years admitted foreign/NRI students beyond the 15% quota cap that the Supreme Court had set in earlier cases (P.A. Inamdar and related rulings). In 2005, the Medical Council of India directed the university not to fill 103 seats in its NRI quota over three academic years (2005-08) as a way of "offsetting" the earlier over-admissions. The university challenged this directive in the Karnataka High Court, which ruled in its favour on the narrow ground that the MCI lacked power to regulate sub-category quotas, but still denied relief because the university had exceeded the cap. The university then appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that the Medical Council of India has no statutory power to fix or regulate quotas within a college's total intake (such as the NRI sub-quota): its role under the Medical Council Act is limited to determining overall intake capacity and ensuring merit-based selection, not dictating how a quota within that intake should be allocated or reduced in later years. Since there was no express or reasonably implied statutory power for the MCI to order the university to leave 103 NRI seats vacant as a penalty for past over-admission, that direction was declared ultra vires (beyond its legal authority) and void. The Court applied the settled principle that what an authority cannot do directly, it also cannot do indirectly through a general "merit-based selection" regulation. The appeal was therefore allowed, with no order as to costs.
Lesson Learnt
A regulatory body can only exercise powers that are expressly given to it by statute (or reasonably implied from it), even where a body has a legitimate underlying concern, such as ensuring merit in admissions, it cannot invent new punitive powers (like withholding future seats) that the law does not actually grant it.