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Modern Dental College and Research Centre & Ors. v. State of Madhya Pradesh & Ors.

Civil Appeal · Neutral citation not assigned (Civil Appeal No. 4060 of 2009, order of 2 May 2016)Decided 2 May 2016
Civil Appeal No. 4060 of 2009
Justice Anil R. Dave · Justice A.K. Sikri · Justice R.K. Agrawal · Justice Adarsh Kumar Goel · Justice R. Banumathi

Background

Several private, unaided medical and dental colleges in Madhya Pradesh challenged a 2007 state law (and rules framed under it) that regulated admission procedures, fee fixation, and reservation of seats in private professional colleges. The colleges argued this violated their fundamental right under Article 19(1)(g) of the Constitution to run their institutions as they chose, including freely setting fees and admission criteria, relying on the Supreme Court's earlier eleven-judge ruling in T.M.A. Pai Foundation. The Madhya Pradesh High Court had already upheld the law, and the colleges appealed to the Supreme Court.

Decision Breakdown

The Supreme Court dismissed the appeals and upheld the Madhya Pradesh High Court's judgment, holding that the State had legislative competence to enact the 2007 Act and that regulating admission (through a common entrance test) and fee fixation did not violate Article 19(1)(g) once read with the reasonable-restrictions clause in Article 19(6). The Court held that while private unaided institutions have autonomy to manage admissions and fees, this autonomy must be balanced against preventing capitation fees and profiteering, consistent with the principles laid down in T.M.A. Pai, Islamic Academy of Education, and P.A. Inamdar. Separately, noting an unresolved Expert Committee report on reforming the Medical Council of India, the Court used its powers under Article 142 to direct the Central Government to set up a temporary Oversight Committee (headed by a former CJI, Justice R.M. Lodha) to supervise MCI's statutory functions and policy decisions pending a permanent legislative mechanism.

Lesson Learnt

A private college's right to "administer" itself is a protected but not unlimited freedom: the State can validly regulate admission procedures and fees to stop profiteering and capitation-fee charging, as long as the regulation is reasonable and transparent rather than an outright takeover of the institution's management.

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

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