Supreme Court Approves Excess Admissions in Siddha Medical College: Ministry of Health vs. A.T.S.V.S. Siddha Medical College (2019) INSC 87

Date of the Judgment: February 08, 2019

Citation: (2019) INSC 87

Judges: L. Nageswara Rao, J., Sanjay Kishan Kaul, J.

Can a medical college’s unauthorized admissions be validated to protect the future of students? The Supreme Court of India addressed this critical question in a case involving the A.T.S.V.S. Siddha Medical College, where students were admitted beyond the sanctioned intake. The court had to decide whether to uphold the High Court’s direction to allow these students to continue their studies despite the lack of proper approvals. The judgment was delivered by a two-judge bench comprising Justice L. Nageswara Rao and Justice Sanjay Kishan Kaul.

Case Background

The A.T.S.V.S. Siddha Medical College was initially granted permission to admit 40 students for the Bachelor of Siddha Medicine and Surgery (BSMS) course. However, based on an interim order by the High Court, the college admitted 58 students for the academic year 2015-2016, exceeding the sanctioned intake by 18 students. For the academic year 2016-2017, the college was not granted permission to admit any students. Despite this, the college admitted 39 students, again based on an interim order from the High Court. This led to a dispute regarding the future of these students who were admitted without proper approval from the Ministry of Health and Family Welfare, Department of AYUSH.

Timeline:

Course of Proceedings

The High Court of Madras directed the Appellant to approve the admission of students who were admitted over and above the approved intake of 40 seats for the academic year 2015-2016. The High Court also directed the Respondents to announce the results of the examinations of all the students including those who have been admitted over and above the approved intake. The Supreme Court, after hearing both sides, directed that the results of the students admitted for the years 2015-2016 and 2016-2017 be declared, subject to an inspection to evaluate the infrastructure and facilities. The Central Council of Indian Medicine (CCIM) conducted an inspection, and based on the report, the Appellant refused permission for the admissions. The Supreme Court noted that the refusal was in violation of the court’s previous order.

Legal Framework

The judgment refers to Section 13(4) of the Indian Medicine Central Council Act, 1970, which deals with the inspection of medical colleges and the submission of reports to the Central Government. The relevant portion of the Act was not quoted in the source document. The court also considered the regulations governing the infrastructure and facilities required for medical colleges.

Arguments

Arguments on behalf of the Appellant (Union of India):

• The Union of India argued that the first Respondent-College was not entitled to permission for the academic years 2015-2016 and 2016-2017.
• They contended that the assessment of infrastructure and other requirements for 2015-2016 and 2016-2017 could not be made based on an inspection conducted in November 2018.
• They stated that the college did not permit an inspection to be conducted for the year 2016-2017.
• The Additional Solicitor General submitted that certain deficiencies still exist in the college.

Arguments on behalf of the Respondent (A.T.S.V.S. Siddha Medical College):

• The Respondent-College argued that the college has all the facilities that are required in accordance with the Regulations.
• They contended that the inspection report did not reveal any serious deficiencies.
• They sought a direction to the University to conduct special examinations for the students.

The core of the dispute was whether the students admitted in excess of the sanctioned intake should be allowed to continue their studies. The Union of India argued that the inspection conducted in 2018 could not assess the conditions of 2015-2016 and 2016-2017, while the college argued that the facilities were adequate.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section. However, the core issue was:

1. Whether the refusal by the Union of India to grant permission to the students admitted in excess of the sanctioned strength was valid, given the previous order of the Supreme Court.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The judgment does not cite any case laws or books. The court relied on its own previous order dated 27th September, 2018, in the same case, to direct the inspection and declaration of results. The court also considered Section 13(4) of the Indian Medicine Central Council Act, 1970, which deals with the inspection of medical colleges and the submission of reports to the Central Government. The court also considered the regulations governing the infrastructure and facilities required for medical colleges.

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• The previous order of the Supreme Court dated 27th September, 2018* was followed, and the court emphasized that its previous order had directed an inspection to assess existing infrastructure, and the refusal based on the impossibility of assessing past conditions was a violation of this order.
• Section 13(4) of the Indian Medicine Central Council Act, 1970* was considered, the court noted that the inspection report was submitted under this section, but the refusal of permission based on the report was deemed invalid.
• The Regulations governing infrastructure and facilities for medical colleges* were considered, the court noted that the inspection report did not reveal any serious deficiencies, suggesting compliance with these regulations.

What weighed in the mind of the Court?

The Supreme Court was primarily concerned with ensuring that the students who were admitted based on the High Court’s interim orders were not penalized for the college’s actions. The court emphasized that its previous order was clear about the purpose of the inspection, which was to assess the existing infrastructure and facilities, not to determine whether the college had sufficient infrastructure in the past. The court also noted that the inspection report did not reveal any serious deficiencies, which weighed in favor of allowing the students to continue their studies.

Logical Reasoning:

The Court stated, “The refusal by the Union of India to truthfully carry out the orders passed by this Court in the Civil Appeal Nos. 10023-10024 of 2018 prompts us to direct the approval of admissions of the 18 students in excess of the sanctioned intake of 40 seats for the year 2015-2016 and the 39 students for the year 2016-2017.” The court also noted, “The inspection that was to be conducted pursuant to the order of this Court was for assessing the existing infrastructure and other facilities.” Finally, the court clarified, “This order shall not be treated as a precedent as it is passed in the peculiar facts of the case.”

Key Takeaways

• Students admitted in excess of the sanctioned intake were allowed to continue their studies and take examinations.
• The Supreme Court emphasized the importance of adhering to its orders and the purpose of the inspection.
• The court disapproved of the college’s conduct in admitting students without permission.
• The judgment is specific to the facts of the case and should not be treated as a precedent.

Directions

The Supreme Court directed the approval of admissions of the 18 students in excess of the sanctioned intake of 40 seats for the year 2015-2016 and the 39 students for the year 2016-2017. The court also directed that the said students shall be permitted to take the examinations and the results may be announced.

Development of Law

The ratio decidendi of this case is that when a court directs an inspection for a specific purpose, the inspection should be conducted and interpreted in line with the direction. The court clarified that the inspection was for assessing the existing infrastructure and facilities, not for assessing if the college had facilities in 2015-2016 and 2016-2017. This ruling reinforces the need for authorities to adhere to court orders and not to interpret them in a way that defeats their purpose. The Supreme Court made it clear that this order shall not be treated as a precedent as it is passed in the peculiar facts of the case.

Conclusion

The Supreme Court’s judgment in this case highlights the importance of adhering to court orders and ensuring that students are not penalized for the actions of educational institutions. The court directed the approval of excess admissions and the announcement of results, emphasizing that the inspection was for assessing the existing infrastructure and facilities. This decision underscores the court’s commitment to protecting the interests of students while also holding educational institutions accountable for their actions.