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Medical Council of India v. Lord Buddha Educational Society & Others

Civil Appeal · 2018 INSC 943Decided 9 Oct 2018
Civil Appeal No. 10352 of 2018
Justice Arun Mishra · Justice Vineet Saran

Background

A medical college in Chhattisgarh had been granted only conditional permission to admit MBBS students, subject to removing infrastructure and faculty deficiencies found at inspection. Repeated inspections in 2016 and 2017 found serious, continuing deficiencies, including a shortage of qualified faculty and residents, low genuine bed occupancy, and patients who appeared to have been brought in from old-age homes simply to inflate numbers, leading the Medical Council of India (MCI) and the central government to refuse renewal of permission for the college's third batch of MBBS admissions. The college successfully challenged this refusal before the Delhi High Court, which directed MCI to allow a fresh compliance inspection; MCI then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that under Regulation 8(3)(1)(a) of the Establishment of Medical College Regulations, 1999, once a college's deficiencies exceed the prescribed thresholds (more than 30% faculty/resident shortage, or bed occupancy below 50%), the college is not entitled to a further opportunity to fix the deficiencies for that academic year: compliance verification is simply barred by the regulation. It found that the college's deficiencies (21% faculty shortage, 24.48% resident shortage, only 33% genuine bed occupancy) clearly crossed this threshold, and that the High Court had misread an earlier Supreme Court order as requiring a fresh compliance opportunity regardless of how severe the deficiencies were. The Court therefore set aside the High Court's judgment and restored the government's refusal to renew permission for the academic year in question.

Lesson Learnt

Medical colleges with serious, documented deficiencies in faculty, patients, or infrastructure are not automatically entitled to a "second chance" to fix problems before an admission cycle: regulations setting hard thresholds for patient safety and educational quality are enforced strictly, and courts will not read vague general directions as overriding specific regulatory safeguards.

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

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