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Medical Council of India v. The Principal, KMCT Medical College & Anr.

Civil Appeal · 2018 INSC 743Decided 21 Aug 2018
Civil Appeal No. 8429 of 2018
Justice S.A. Bobde · Justice L. Nageswara Rao

Background

KMCT Medical College sought renewal of permission to admit a third batch of 150 MBBS students for 2018-19, after an earlier inspection flagged deficiencies (e.g., a single-slice CT scanner, a short examination hall). A Hearing Committee found two deficiencies appeared rectified and suggested the Medical Council of India (MCI) review without fresh verification, but MCI instead conducted a second inspection in March 2018, which found numerous new deficiencies (faculty and resident shortages, padded patient admissions, inadequate examination hall capacity) and recommended against renewal, capping admission at 100 seats. The College successfully challenged this before the Kerala High Court, which held MCI was bound to follow the Hearing Committee's suggestion and ordered the College be allowed to admit 150 students; MCI appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that MCI, as the expert statutory body safeguarding medical education standards, is not barred from conducting a second or subsequent inspection, even close on the heels of an earlier one, and is not restricted to re-verifying only the specific deficiencies flagged before: it may examine compliance with minimum standards generally. The Hearing Committee's suggestion that MCI "may" skip fresh verification was only a suggestion, not a binding direction, and the manner of compliance verification is left to MCI's discretion as the body empowered to conduct physical inspection. The Court reiterated that an expert body's decision on adequacy of medical college facilities should not be lightly disturbed by courts absent jurisdictional error, patent perversity, or mala fide, none of which the College had shown here. The High Court's judgment was therefore set aside and MCI's appeal allowed, restoring MCI's recommendation against the enhanced intake.

Lesson Learnt

Expert regulatory bodies like the Medical Council of India retain broad discretion to re-inspect and reassess compliance with safety/quality standards (such as hospital infrastructure and staffing in medical colleges), and courts will not second-guess such expert technical findings unless there is clear illegality or bad faith.

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

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