Tamil Nadu Dr. MGR Medical University v. SVS Educational and Social Trust
Background
SVS Educational and Social Trust ran a homeopathy college whose request to continue provisional affiliation for admitting BHMS students for 2016-17 was rejected by Tamil Nadu Dr. MGR Medical University for failing to fix inspection-flagged deficiencies. The Trust challenged this in the Madras High Court, which directed the University to let the Trust participate in counselling and admit students for 2017-18 even while the case was pending, and a Division Bench upheld that interim relief without giving reasons. The University appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that the Trust never had the mandatory prior approval from the Central Government under Section 12A of the Homeopathy Central Council Act, 1973, for the relevant period, and the one-year affiliation consent earlier granted had lapsed, so the University was right to refuse continuance of provisional affiliation. The Court found the High Court erred in assuming the earlier approval remained valid without renewal, and in granting admission relief without first deciding whether the Trust actually held the required Central Government approval. It reiterated that courts should not pass interim orders allowing provisional student admissions pending litigation, since this risks students losing years of study if the case is ultimately lost. The High Court's order was set aside and the University's appeal was allowed.
Lesson Learnt
Educational institutions must hold current, valid regulatory approvals (not just a one-time past approval) before each admission cycle, and courts are cautious about ordering provisional student admissions mid-litigation because of the harm to students if the institution later loses the case.