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Sree Balaji Medical College and Hospital & Anr. v. Union of India & Anr.

Writ Petition (Civil) · Neutral citation not assigned (Writ Petition (Civil) No. 306 of 2015)Decided 6 Aug 2015
Writ Petition (Civil) No. 306 of 2015
Justice Anil R. Dave · Justice Kurian Joseph

Background

Sree Balaji Medical College sought to increase its MBBS admission capacity from 150 to 250 seats, but the Medical Council of India (MCI) rejected the request on the basis of an internal committee decision (dated 14.03.2014) that no college could get an increase unless its existing (lower) admission strength was itself formally "recognized" by the Central Government first. The college argued this requirement had no basis in the Indian Medical Council Act, 1956 or its regulations, and approached the Supreme Court directly under Article 32 after the MCI relied on this policy to deny the increase.

Decision Breakdown

The Supreme Court examined Sections 10A and 11 of the Act and the applicable 2000 Regulations and held that the Act does not require separate "recognition" of admission capacity (as distinct from recognition of the course/qualification itself) before capacity can be increased: recognition under Section 11 applies to medical qualifications, not to a specific seat count. The Court found the MCI's 14.03.2014 policy decision had no legal basis and was therefore to be disregarded, especially noting that two other colleges (S.P. Medical College, Bikaner and Maulana Azad Medical College, Delhi) had been granted capacity increases without this same recognition precondition being applied. It rejected the MCI's objection that the writ was not maintainable, since the facts were undisputed and the dispute was purely a question of law suitable for Article 32. The Court allowed the writ petition, quashed the impugned orders, and directed the respondents to reconsider the college's application for the increase from 150 to 250 seats for the 2015-16 academic session and pass a fresh decision within two weeks.

Lesson Learnt

A regulatory body cannot impose extra preconditions on a statutory benefit (like increasing medical college seats) that are not actually found in the governing Act or its regulations, and inconsistent treatment of similarly situated institutions can itself be a ground for striking down such an informal policy.

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

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