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Royal Medical Trust and Another v. Union of India and Another

Writ Petition (Civil) · 2017 INSC 889Decided 12 Sept 2017
Writ Petition (Civil) No. 747 of 2017
Chief Justice Dipak Misra · Justice Amitava Roy · Justice A.M. Khanwilkar

Background

The petitioner-Trust ran Kerala Medical College, Palakkad, and challenged a Central Government order debarring it from admitting 150 MBBS students for 2017-18 and 2018-19, and threatening to encash its Rs. 2 crore bank guarantee. The college's earlier applications for a Letter of Permission (LOP) had run into repeated negative recommendations from the MCI over inspection deficiencies, with the Court-appointed Oversight Committee (constituted under the Constitution Bench's Modern Dental College judgment) intervening at various stages to approve LOP subject to conditions. The petitioners sought to quash the debarment orders and compel renewal of permission for 2017-18.

Decision Breakdown

The Court held that while its first debarment order (31 May 2017) was unreasoned, the later order (14 August 2017) reiterating the debarment was adequately reasoned when read as a whole, and that judicial review of such regulatory decisions is not an appellate re-appreciation of the merits: courts intervene only where a decision is irrational or devoid of reasons (applying Wednesbury principles). Since the cut-off date for 2017-18 admissions had already passed, the Court declined to order fresh admissions for that year, but allowed students already studying under the 2016-17 LOP to continue their course, directed that the college's renewal application be treated as one for 2018-19, ordered a fresh MCI inspection within two months with an opportunity for the college to cure deficiencies, and restrained the MCI from encashing the bank guarantee in the meantime. The writ petition was disposed of in these terms.

Lesson Learnt

Courts reviewing a regulator's technical/administrative decision (like MCI's medical-college recognition process) will not substitute their own judgment on the merits: they only check whether the decision-maker gave reasons and acted rationally; even where relief for a lapsed academic year is refused, the court can still protect students already admitted and give the institution a fair chance to fix deficiencies for the future.

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

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