ANMOL versus UNION OF INDIA & ORS.

ANMOL versus UNION OF INDIA & ORS.

Appendix H-1 to the NMC Graduate Medical Education Regulations of 13.05.2019 cannot be interpreted to disqualify a candidate solely on the basis of quantified disability; Disability Assessment Boards must perform individual functional competency assessments, record reasons when denying eligibility, and consider reasonable accommodation and assistive technologies on a case-by-case basis; courts can ensure Boards follow these legal requirements and may direct independent expert assessment where necessary; accordingly, the appellant who was found functionally competent by an expert report is entitled to admission and the High Court order rejecting his plea is set aside.

Parties
Appellant: Anmol; Respondent: Union of India & Ors.
Jurisdiction
India
Judgment Date
21 February 2025
Procedural Posture
Civil Appeal / Appeal to Supreme Court (civil Appeal Hearing and Final Judgment)
Outcome
Appeal allowed; High Court order dated 23.09.2024 set aside; admission of appellant to MBBS at Government Medical College, Sirohi confirmed
Legal Topics
Reasonable Accommodation, Disability Assessment Boards, Medical Education Admissions, NMC Guidelines, Functional Assessment
Disability Law Constitutional Law Administrative Law Education Law Health/medical Regulation Reasonable Accommodation Disability Assessment Boards Medical Education Admissions +2 more

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Parties

Anmol

Appellant

Union of India & Ors.

Respondent

Procedural Posture

Civil Appeal / Appeal to Supreme Court (civil Appeal Hearing and Final Judgment)

Legal Issues

  1. 1 Whether quantified disability per se can disqualify a candidate from MBBS admission under Appendix H-1 to the NMC Regulations
  2. 2 Whether Disability Assessment Boards must carry out functional assessment and record reasons before denying admission
  3. 3 What is the scope of reasonable accommodation under the RPwD Act in medical education

Ratio Decidendi

Appendix H-1 to the NMC Graduate Medical Education Regulations of 13.05.2019 cannot be interpreted to disqualify a candidate solely on the basis of quantified disability; Disability Assessment Boards must perform individual functional competency assessments, record reasons when denying eligibility, and consider reasonable accommodation and assistive technologies on a case-by-case basis; courts can ensure Boards follow these legal requirements and may direct independent expert assessment where necessary; accordingly, the appellant who was found functionally competent by an expert report is entitled to admission and the High Court order rejecting his plea is set aside.

Court Disposition

Appeal allowed; High Court order dated 23.09.2024 set aside; admission of appellant to MBBS at Government Medical College, Sirohi confirmed

Orders

  • Judgment and order dated 23.09.2024 of the High Court of Punjab & Haryana in CWP No. 24293 of 2024 set aside
  • Admission of the appellant to MBBS in Government Medical College, Sirohi (against a PwD OBC seat) as directed by this Court's order dated 12.12.2024 is confirmed