Supreme Court allows MBBS admission for disabled student, emphasizing functional assessment: Anmol vs. Union of India (2025) INSC 256 (21 February 2025)

Introduction

Date of the Judgment: 21st February, 2025

Citation: 2025 INSC 256

Judges: B.R. Gavai, J., K.V. Viswanathan, J.

Can a medical aspirant be denied admission solely based on the percentage of disability, without a proper assessment of their functional capabilities? The Supreme Court of India addressed this critical question in the case of Anmol v. Union of India & Ors., concerning the admission of a student with disabilities to the MBBS course.

The Supreme Court allowed the appeal, confirming the admission of the appellant, who has a locomotor disability and speech impairment, to the MBBS course. The Court emphasized the need for a functional assessment of a candidate’s abilities rather than relying solely on the quantified percentage of disability.

The judgment was delivered by a bench comprising Justice B.R. Gavai and Justice K.V. Viswanathan.

Case Background

The appellant, Anmol, demonstrated a strong academic record throughout schooling. After appearing for the NEET-UG 2024 Examination on 05.05.2024, Anmol secured a rank of 2462 in the Persons with Disability (PwD) category, surpassing the cut-off for the OBC-PwD category.

Anmol’s disability includes Locomotor disability 50% with Club foot right lower limb with Phocomelia, Left middle ring finger through middle phalanx with right middle index finger through middle phalanx, and a speech and language disability of 20%. The final disability was computed at 58%.

On approaching the Government Medical College, Chandigarh (Respondent No. 6), a designated Disability Certification Centre, the Disability Assessment Board deemed Anmol ineligible for the medical course based on the quantified disability, without examining the functional disability.

Aggrieved by this decision, the appellant filed Civil Writ Petition No. 24293 of 2024 before the High Court, seeking to quash the disability certificate and request a fresh assessment. The High Court dismissed the petition, stating that it could not substitute the opinion of disability experts.

Timeline:

Legal Framework

The case revolves around the interpretation and application of the Rights of Persons with Disabilities Act, 2016 (RPwD Act) and the Guidelines under the Regulations regarding admission of students with “Specified Disabilities” in the MBBS Course, which constitute Appendix H-1 to the Graduate Medical Education Regulations (Amendment), 2019, notified on 13.05.2019.

The relevant provisions include:

• Rights of Persons with Disabilities Act, 2016: This Act aims to ensure full and effective participation and inclusion of persons with disabilities in society.
• Appendix H-1 to the Graduate Medical Education Regulations (Amendment), 2019: This appendix specifies the eligibility criteria for students with disabilities seeking admission to the MBBS course.

The key point of contention is the interpretation of the guidelines, particularly the requirement that “Both hands intact, with intact sensations, sufficient strength and range of motion are essential to be considered eligible for medical course.” The Supreme Court examines whether this requirement aligns with the objectives of the RPwD Act and the principles of reasonable accommodation.

Arguments

Arguments by the Appellant:

• The appellant contended that the mechanical and literal interpretation of the guidelines rendered him ineligible, which is against the principles of the RPwD Act.
• The appellant emphasized the need for a functional assessment of his abilities rather than relying solely on the quantified percentage of disability.
• The appellant relied on the communication of 25.01.2024 issued by the Ministry of Social Justice and Empowerment, which mandated the review of regulations by the National Medical Commission (NMC).

Arguments by the Respondents:

• The respondents argued that the High Court cannot substitute the opinion of the experts in the field of disability.
• The respondents relied on the existing guidelines, which require that “Both hands intact, with intact sensations, sufficient strength and range of motion are essential to be considered eligible for medical course.”

Submissions Table:

Issues Framed by the Supreme Court

1. Whether the disability suffered by the petitioner would come in the way of his pursuing medical studies.
2. Whether the existing guidelines, particularly the requirement of “both hands intact,” are consistent with the Rights of Persons with Disabilities Act, 2016 and the principles of reasonable accommodation.
3. Whether a functional assessment of a candidate’s abilities is necessary for determining eligibility for the MBBS course.

Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”

Authorities

The Supreme Court considered several cases, legal provisions, and guidelines to reach its decision. These authorities were categorized by specified legal points.

Judgment

The Supreme Court allowed the appeal, setting aside the judgment of the High Court and confirming the admission granted to the appellant. The Court’s decision was based on a detailed analysis of the facts, legal provisions, and previous judgments.

How each authority was viewed by the Court?

• Omkar Ramchandra Gond v. Union of India & Ors., 2024 SCC OnLine SC 2860 [Supreme Court of India]: The Court relied upon this authority and highlighted that merely based on the quantification of the disability, a candidate will not forfeit his right to stake a claim for admission to the course of his or her choice.
• Vikash Kumar v. Union Public Service Commission & Ors., (2021) 5 SCC 370 [Supreme Court of India]: The Court relied upon this authority and expanded on the concept of reasonable accommodation elucidated therein.
• Om Rathod v. Director General of Health Services & Ors., 2024 SCC Online SC 3130 [Supreme Court of India]: The Court relied upon this authority and reinforced the holding in Omkar Ramchandra Gond (supra) and distinguished the earlier judgment of this Court in Vidhi Himmat Katariya v. Union of India (2019) 10 SCC 20.
• Vidhi Himmat Katariya v. Union of India (2019) 10 SCC 20 [Supreme Court of India]: The Court distinguished this case by holding that the judgment of the Court in Vidhi Himmat Katariya (supra) was specific to the facts of that case and did not involve any question of interpretation or Constitutional analysis.

What weighed in the mind of the Court?

The Supreme Court’s decision in Anmol v. Union of India was influenced by several factors, including the need to protect the rights of persons with disabilities, the importance of functional assessment, and the principles of reasonable accommodation. The Court emphasized that a candidate should not be denied admission solely based on the percentage of disability, without a proper assessment of their functional capabilities.

Fact:Law Ratio

Logical Reasoning:

For the issue of whether the disability suffered by the petitioner would come in the way of his pursuing medical studies, the court’s logical reasoning is as follows:

Key Takeaways

• Functional assessment is crucial in determining the eligibility of candidates with disabilities for medical courses.
• The “both hands intact” prescription is antithetical to the rights of persons with disabilities and the principles of reasonable accommodation.
• Disability Assessment Boards must provide detailed reasons for denying admission to candidates with disabilities.
• The National Medical Commission (NMC) is directed to formulate revised guidelines in accordance with the judgments of the Supreme Court.

Directions

The Supreme Court directed the National Medical Commission (NMC) to formulate revised guidelines in accordance with the judgments of the Court, as directed in Omkar Ramchandra Gond (supra) and Om Rathod (supra). The Court further directed that the NMC shall file an affidavit explaining the current status before the said hearing date.

The Court directed this matter to be posted on 03.03.2025 to consider whether the National Medical Commission has formulated the revised guidelines in accordance with the judgments of this Court.

Development of Law

The ratio decidendi of the case is that quantified disability per se will not dis-entitle a candidate with benchmark disability from being considered for admission to educational institutions. The candidate will be eligible if the Disability Assessment Board opines that notwithstanding the quantified disability the candidate can pursue the course in question.

This judgment changes the previous position of law by emphasizing the importance of functional assessment and reasonable accommodation in determining the eligibility of candidates with disabilities for medical courses.

Conclusion

In Anmol v. Union of India, the Supreme Court allowed the appeal, confirming the admission of the appellant to the MBBS course. The Court emphasized the need for a functional assessment of a candidate’s abilities rather than relying solely on the quantified percentage of disability. The judgment reinforces the rights of persons with disabilities and promotes the principles of reasonable accommodation.