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Poonaiyah Ramajayam Institute of Science and Technology Trust v. Medical Council of India

Special Leave Petition (Civil) · Neutral citation not assigned (Special Leave Petition (Civil) No. 14838 of 2015, order of 17 September 2015)Decided 17 Sept 2015
Special Leave Petition (Civil) No. 14838 of 2015
Justice M.Y. Eqbal · Justice C. Nagappan

Background

The petitioner-Trust applied in 2014 to establish a new medical college for the 2015-16 academic year, but its Essentiality Certificate and Affiliation Consent were submitted on 10.9.2014, after the government's 31.8.2014 cut-off, leading the Central Government to reject the application. The Delhi High Court's Single Judge ruled in the Trust's favour and directed the Medical Council of India (MCI) to consider the application, but a Division Bench reversed that on appeal, prompting this SLP. On an earlier hearing (15.7.2015), the Supreme Court had directed the MCI to inspect the institute and submit its recommendation in a sealed cover.

Decision Breakdown

The MCI's inspection report, now placed before the Court, revealed serious deficiencies at the institute, including an 83% faculty shortage, a 100% resident-doctor shortage, grossly inflated OPD attendance figures, no patients in the casualty ward or operation theatres on the day of inspection, and shared engineering-college infrastructure, leading the MCI's executive committee to recommend disapproval of the scheme for both 2015-16 and 2016-17. Relying on its own contemporaneous ruling in a companion case (Padmashree Dr. D.Y. Patil Medical College v. MCI, decided 31.8.2015) that statutory admission time schedules must be strictly followed and cannot be relaxed once already expired, the Court held that no positive direction could be issued to admit students for the already-lapsed 2015-16 session, since the Central Government had not yet even taken a final call on the MCI's report. The Court expressly declined to comment on the merits of the MCI's recommendation to disapprove the scheme for 2016-17 as well, leaving the petitioner free to challenge that disapproval before the appropriate forum if and when it is finalised by the Central Government.

Lesson Learnt

Courts will not override a strict statutory admission time schedule once it has lapsed, and where a regulatory decision (here, MCI's recommendation) is still pending final approval by the competent authority (the Central Government), the aggrieved party must wait for that final decision and challenge it separately rather than seek a court direction mid-process.

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

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