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Medical Council of India v. The Chairman, S.R. Educational and Charitable Trust & Anr.

Civil Appeal · 2018 INSC 1014Decided 29 Oct 2018
Civil Appeal No. 10372 of 2018
Justice Arun Mishra · Justice Vineet Saran

Background

The Medical Council of India (MCI) appealed against a Kerala High Court judgment that had quashed the Central Government's refusal to grant renewal permission/recognition to four medical colleges (clubbed together in one High Court order), and that had directed immediate admission of students for 2018-2019. The High Court had also directed MCI to re-inspect the colleges to check if deficiencies were cured. This particular appeal concerned S.R. Educational and Charitable Trust's medical college, one of four colleges whose cases the High Court had decided together despite each having different facts and deficiencies.

Decision Breakdown

The Supreme Court held that the High Court erred in deciding four factually distinct cases through one common/clubbed order, since the deficiencies found at each college differed. On the merits, the Court found that given the genuine deficiencies in faculty strength and bed occupancy, the decision to deny permission for fresh admissions for the 2018-2019 academic year was appropriate and could not be faulted. However, the Court ordered that the compliance submitted by the college should still be considered by MCI for the separate purpose of future "recognition" under Regulation 8(3), unaffected by the admission-denial order. The appeals (including this one) were allowed, the High Court's common judgment was set aside, and the colleges were left free to seek admission permission for the next academic year (2019-2020) in accordance with law.

Lesson Learnt

Regulatory bodies like the MCI can validly deny permission for a fresh batch of student admissions where genuine infrastructural deficiencies exist, even while a separate process for long-term institutional recognition continues independently; courts should also avoid deciding factually distinct cases through one clubbed order.

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

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