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Medical Council of India v. G.C.R.G. Memorial Trust & Ors.

Civil Appeal · 2017 INSC 1132Decided 23 Nov 2017
Civil Appeal No. 19662 of 2017
Chief Justice Dipak Misra · Justice A.M. Khanwilkar · Dr. Justice D.Y. Chandrachud

Background

The Central Government had debarred a private medical college (G.C.R.G. Memorial Trust) from admitting students for two years after a Hearing Committee found serious deficiencies, including a severely anaemic maternity patient discharged untreated, mishandled ICU admissions unrelated to cardiac conditions, and unexplained acquisition of 14 cadavers without proper permission. While the Supreme Court was still seized of a related writ petition and had expressly barred the High Court from passing any interim order for that academic year, the college withdrew its Supreme Court petition and filed a fresh writ before the Allahabad High Court, which, without waiting for replies from the Medical Council of India or the Central Government, quashed the debarment and allowed the college to admit students, all within about three days.

Decision Breakdown

The Supreme Court strongly criticized the High Court's judgment as reflecting "unnecessary and uncalled for hurry" and a breach of judicial propriety, noting the Central Government and MCI were denied even an opportunity to file counter-affidavits before the matter was decided. The Court held the High Court had no basis to override the Supreme Court's own directive confining relief to a reconsideration process by the Central Government, confirmed its earlier interim order debarring any students who had been admitted from continuing the course, and upheld the two-year debarment. Because students had been lured into admission by the college's "unholy" conduct, the Court ordered the college to refund their fees and additionally pay Rs. 10 lakh compensation to each affected student, and imposed Rs. 25 lakh in costs on the college to be deposited with the Court. The college's separate request regarding the 2018-2019 academic session was rejected, and the appeal was allowed.

Lesson Learnt

Courts are expected to respect procedural fairness, deciding a case without giving all parties a chance to respond is itself a ground for the Supreme Court to step in and reverse a lower court, and institutions that game the legal process to admit students despite serious compliance failures can be made to personally compensate the students harmed, on top of losing the case.

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

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