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National Medical Commission v. Mothukuru Sriyah Koumudi & Ors.

Civil Appeal · 2020 INSC 683Decided 7 Dec 2020
Civil Appeal No. 3940 of 2020
Justice L. Nageswara Rao · Justice Hemant Gupta

Background

Respondent No. 1, a doctor, was provisionally allotted an MS (General Surgery) postgraduate seat at a Hyderabad medical college through the merit-based counselling process. She claimed she visited the college within the deadline to complete her admission formalities and pay fees, but the college denied her admission and later gave the seat to a candidate ranked about 2000 places below her. The Telangana High Court believed her account, found the college had acted illegally, and directed the National Medical Commission to create an additional seat for her; the Commission appealed that direction to the Supreme Court.

Decision Breakdown

The Supreme Court agreed with the High Court's factual finding that the college had wrongfully denied her admission: the college's own contradictory statements undermined its defence, and there was no valid justification for skipping over her in favour of a lower-ranked candidate. However, the Court held that directing a medical college to create an extra seat beyond its sanctioned intake capacity is not permissible, as this breaches binding Medical Council of India norms, so that part of the High Court's order could not stand. Applying the Court's own precedent on remedies for illegally denied medical admissions, it instead directed the college to pay her Rs. 10 lakh compensation for the lost academic year and guaranteed her a seat in the same course in the following academic year (2021-22) from the college's management quota.

Lesson Learnt

Courts generally cannot order a medical college to exceed its officially sanctioned number of seats, even to remedy a proven wrong, but a student who is illegally denied an admission she rightfully earned is still entitled to meaningful redress, such as compensation plus a guaranteed seat the following year.

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

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