Supreme Court Clarifies Minimum Standards for Ayurveda PG Courses: Central Council for Indian Medicine vs. Karnataka Ayurveda Medical College (2022)

Date of the Judgment: April 11, 2022

Citation: (2022) INSC 364

Judges: L. Nageswara Rao, J., B.R. Gavai, J. (authored the judgment)

Can a medical college admit students to post-graduate courses if it did not meet the minimum infrastructure standards in the previous academic year, even if it met those standards in a subsequent year? The Supreme Court of India recently addressed this critical question concerning the standards for Ayurvedic medical education. The core issue was whether permission granted to an institution for a later academic year could retroactively validate admissions for an earlier year when the institution did not meet the necessary criteria. This judgment clarifies the importance of maintaining minimum standards for medical education and the strict timeline for compliance.

Case Background

The Karnataka Ayurveda Medical College (respondent No. 1) applied for permission to start Post-Graduate (PG) courses for the academic year 2014-15. The Central Council for Indian Medicine (appellant) initially granted permission for five new PG Ayurvedic disciplines, each with five seats, as per the Indian Medicine Central Council (Post-Graduate Ayurveda Education) Regulations, 2012. These regulations were later superseded by the 2016 Regulations.

The 2016 Regulations mandated that institutions possess a Central Research Laboratory and an Animal House. While the Animal House could be owned or in collaboration with another institution, the college collaborated with Sri Dharmasthala Manjunatheshwara College of Ayurveda, Udupi, for the use of their Animal House. The college continued to receive permission for the academic years 2016-17 and 2017-18.

In 2018, the Union of India directed the appellant to inspect the college’s facilities. Inspections were conducted on February 2, 2018, and May 23-24, 2018. Based on these inspections, the Union of India issued a notice on August 3, 2018, pointing out deficiencies. After a hearing on August 24, 2018, the Union of India rejected permission for the college to admit students to PG courses for the academic year 2018-19 due to the lack of a Central Research Laboratory and Animal House. However, permission was granted to admit students to the Under Graduate (BAMS) course with 50 seats, subject to rectifying the deficiencies by December 31, 2018.

The college then filed a writ petition before the High Court of Karnataka. Subsequently, the Union of India granted permission for the college to admit students for the PG course for the academic year 2019-20. The High Court, relying on previous judgments, allowed the writ petition, stating that if permission is granted for subsequent years, it should also apply to the previous year. This decision was challenged by the appellant, leading to the present appeals before the Supreme Court.

Timeline:

Course of Proceedings

The respondent No. 1, Karnataka Ayurveda Medical College, filed Writ Petition No. 50772 of 2018 (EDN-REG-P) before the High Court of Karnataka after the Union of India rejected permission for PG courses for the academic year 2018-19. The learned Single Judge, relying on the judgments of the Division Bench of the High Court of Karnataka in Bahubali Vidyapeeths JV Mandal Gramin Ayurvedic Medical College v. Union of India and Others and Central Council of Indian Medicine v. Union of India and Others, allowed the writ petition. These judgments stated that if permission is granted for subsequent years, the benefit should also apply to the previous year.

The appellant, Central Council for Indian Medicine, appealed the Single Judge’s decision before the Division Bench of the High Court of Karnataka. The Division Bench dismissed the appeal, upholding the Single Judge’s order. The appellant then approached the Supreme Court by way of the present appeals.

Legal Framework

The core legal framework for this case is the Indian Medicine Central Council Act, 1970 (referred to as “the said Act”). This Act was enacted to regulate the standards of education and practice in Indian medicine. Key provisions include:

• Section 13A: This section, introduced by the Indian Medicine Central Council (Amendment) Act, 2003, mandates that no person or medical college can establish a new medical college, open a new or higher course of study (including PG courses), or increase admission capacity without the prior permission of the Central Government. It also outlines the procedure for obtaining such permission, including submitting a scheme to the Central Government, which is then referred to the Central Council for recommendations.

“13A. Permission for establishment of new medical college, new course of study, etc .—(1) Notwithstanding anything contained in this Act or any other law for the time being in force,— (a) no person shall establish a medical college; or (b) no medical college shall— (i) open a new or higher course of study or training, including a post-graduate course of study or training, which would enable a student of such course or training to qualify himself for the award of any recognised medical qualification; or (ii) increase its admission capacity in any course of study or training including a postgraduate course of study or training, except with the previous permission of the Central Government obtained in accordance with the provisions of this section.”

• Section 22: This section empowers the Central Council to prescribe the minimum standards of education in Indian medicine required for granting recognized medical qualifications.

“22. Minimum standards of education in Indian medicine.—(1) The Central Council may prescribe the minimum standards of education in Indian medicine, required for granting recognised medical qualifications by Universities, Boards or medical institutions in India.”

• Section 36: This section empowers the Central Council to make regulations to carry out the purposes of the Act, with the previous sanction of the Central Government. This includes regulations for standards of staff, equipment, accommodation, training, and other facilities for education in Indian medicine.

“36. Power to make regulations .— (1) The Central Council may, with the previous sanction of the Central Government, by notification in the Official Gazette, make regulations generally to carry out the purposes of this Act, and, without prejudice to the generality of this power, such regulations may provide for— (j) the standards of staff, equipment, accommodation, training and other facilities for education in Indian medicine;”

The 2016 Regulations, framed under the Act, specify that institutions must meet minimum infrastructure and teaching standards by December 31 of each year to be considered for permission for the following academic year.

The interplay of these provisions establishes a framework where medical colleges must adhere to strict standards and procedures to obtain permission for starting new courses or increasing admissions, ensuring quality in medical education.

Arguments

The arguments presented before the Supreme Court can be categorized as follows:

Arguments by the Appellant (Central Council for Indian Medicine):

• The 2016 Regulations, framed under Section 36 of the Indian Medicine Central Council Act, 1970, with the Central Government’s sanction, prescribe minimum standards for granting permission to start Post Graduate courses.
• The appellant argued that these minimum standards must be met for each specific academic year. If an institution fails to meet these standards for a particular year, it cannot be granted permission for that year, regardless of whether it meets the standards in subsequent years.
• The appellant contended that the High Court erred in holding that permission granted for a subsequent academic year would automatically apply to a previous year where deficiencies existed.
• The appellant emphasized that the High Court failed to apply the law laid down in the Supreme Court’s judgment in Ayurved Shastra Seva Mandal and Another v. Union of India and Others, which held that fulfilling requirements in a later year does not negate deficiencies of an earlier year.

Arguments by the Union of India:

• The Union of India supported the submissions made by the appellant, emphasizing the need for strict adherence to minimum standards for each academic year.

Arguments by the Respondent (Karnataka Ayurveda Medical College):

• The respondent argued that the High Court’s view was based on its earlier judgments, and therefore, no interference was warranted.
• The respondent contended that since permission was granted for the subsequent academic year (2019-20), it should also apply to the previous academic year (2018-19) as deficiencies were rectified.

[TABLE] of Submissions:

Issues Framed by the Supreme Court

The Supreme Court framed the following key issue for adjudication:

1. Whether the permission granted to an institution for a subsequent academic year can be considered as a validation of the permission for the previous academic year, wherein the institution did not fulfill the minimum standards for infrastructure and other facilities as required under the relevant regulations.

Treatment of the Issue by the Court

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

Authorities

The Supreme Court considered the following authorities:

Cases:

• Ayurved Shastra Seva Mandal and Another v. Union of India and Others [ (2013) 16 SCC 696 ]: The Supreme Court discussed the importance of maintaining minimum standards for medical education and held that permission granted for a subsequent academic year does not validate deficiencies of a previous year. This case was crucial in the Supreme Court’s reasoning.
• Bahubali Vidyapeeths JV Mandal Gramin Ayurvedic Medical College v. Union of India and Others: This case was relied upon by the High Court of Karnataka to allow the writ petition.
• Central Council of Indian Medicine v. Union of India and Others: This case was also relied upon by the High Court of Karnataka to allow the writ petition.

Legal Provisions:

• Indian Medicine Central Council Act, 1970:
  • Section 13A: Mandates prior permission from the Central Government for establishing a medical college or opening a new course.
  • Section 22: Empowers the Central Council to prescribe minimum standards of education.
  • Section 36: Empowers the Central Council to make regulations for the purposes of the Act.
• Indian Medicine Central Council (Post-Graduate Ayurveda Education) Regulations, 2012: The regulations in force when the college initially received permission.
• Indian Medicine Central Council (Post-Graduate Ayurveda Education) Regulations, 2016: The regulations that superseded the 2012 regulations and required a Central Research Laboratory and an Animal House.

[TABLE] of Authorities Considered:

Judgment

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

How each authority was viewed by the Court?

• Ayurved Shastra Seva Mandal and Another v. Union of India and Others [(2013) 16 SCC 696]: The Court followed this judgment, emphasizing that it was not correctly applied by the High Court. The Supreme Court reiterated that deficiencies in one academic year cannot be cured by compliance in a subsequent year.
• Bahubali Vidyapeeths JV Mandal Gramin Ayurvedic Medical College v. Union of India and Others and Central Council of Indian Medicine v. Union of India and Others: The Court overruled these cases, stating that the High Court erred in relying on them.

What weighed in the mind of the Court?

The Supreme Court’s decision was heavily influenced by the need to uphold the statutory scheme of the Indian Medicine Central Council Act, 1970, and the regulations framed thereunder. The Court emphasized that the minimum standards for infrastructure and facilities must be met for each academic year, and permission granted for a subsequent year cannot retroactively validate admissions for a previous year where those standards were not met. The Court also emphasized the importance of maintaining the quality of medical education and ensuring that institutions adhere to the prescribed standards.

The Supreme Court was also concerned that the High Court had not followed the precedent set by the Supreme Court itself in the case of Ayurved Shastra Seva Mandal. This was a crucial factor in the Supreme Court’s decision to overturn the High Court’s judgment.

[TABLE] of Sentiment Analysis:

Fact:Law Ratio:

The Court’s reasoning was primarily driven by the legal framework and the need to ensure that the standards set by the Act and regulations are strictly followed. While the factual aspects of the case were considered, the legal principles and precedents played a more significant role in the Court’s decision.

Logical Reasoning

Key Takeaways

• Strict Adherence to Standards: Medical institutions must meet the minimum standards for infrastructure and facilities prescribed by the Central Council for Indian Medicine for each academic year.
• No Retroactive Validation: Permission granted for a subsequent academic year does not retroactively validate admissions for a previous year where the institution did not meet the required standards.
• Importance of Compliance: Institutions must comply with the regulations by the specified deadlines (December 31 of each year) to be eligible for permission for the following academic year.
• Precedent Matters: The Supreme Court emphasized that High Courts must follow the precedents set by the Supreme Court itself.
• Quality of Medical Education: The judgment underscores the importance of maintaining the quality of medical education and ensuring that institutions adhere to the prescribed standards.

Potential Future Impact: This judgment sets a clear precedent for the regulation of medical education in India, particularly in the field of Indian medicine. It reinforces the strict timelines for compliance and emphasizes the need for institutions to adhere to the prescribed standards, ensuring that the quality of medical education is not compromised. This ruling will likely lead to more rigorous enforcement of standards by regulatory bodies.

Directions

The Supreme Court quashed and set aside the judgments of the Division Bench and the Single Judge of the High Court of Karnataka. The writ petitions filed by the original writ petitioners in the High Court were dismissed.

Development of Law

The ratio decidendi of this case is that permission granted to a medical institution for a subsequent academic year does not validate admissions for a previous academic year where the institution failed to meet the minimum prescribed standards. This judgment reinforces the principle that each academic year is a distinct period for compliance with regulatory standards, and deficiencies in one year cannot be cured by compliance in a subsequent year.

This judgment clarifies the position of law and reiterates the importance of adhering to the minimum standards prescribed by the Indian Medicine Central Council Act, 1970, and the regulations framed thereunder. It also clarifies that the High Courts must follow the precedents set by the Supreme Court itself. There is a change in the previous position of law taken by the High Court of Karnataka.

Conclusion

The Supreme Court’s judgment in Central Council for Indian Medicine vs. Karnataka Ayurveda Medical College clarifies that medical institutions must meet minimum standards for each academic year, and permission for a later year does not retroactively validate prior admissions where standards were not met. This ruling reinforces the need for strict adherence to regulations and ensures the quality of medical education in India.

Category

Parent Category: Indian Medicine Central Council Act, 1970

Child Categories:

• Section 13A, Indian Medicine Central Council Act, 1970
• Section 22, Indian Medicine Central Council Act, 1970
• Section 36, Indian Medicine Central Council Act, 1970
• Minimum Standards for Medical Education
• Ayurveda Education Regulations
• Post-Graduate Medical Courses
• Medical College Permissions

FAQ

Q: What is the main issue addressed in this Supreme Court judgment?

A: The main issue is whether permission granted to an Ayurvedic medical college for a subsequent academic year can validate admissions for a previous year when the college did not meet the required minimum standards.

Q: What did the Supreme Court decide regarding this issue?

A: The Supreme Court decided that permission granted for a subsequent academic year does not retroactively validate admissions for a previous year when the college did not meet the required minimum standards. The Court emphasized that minimum standards must be met for each academic year.

Q: What are the key legal provisions discussed in the judgment?

A: The key legal provisions discussed include Section 13A, Section 22, and Section 36 of the Indian Medicine Central Council Act, 1970. These sections deal with the establishment of medical colleges, the prescription of minimum standards of education, and the power to make regulations, respectively.

Q: What are the implications of this judgment for medical colleges?

A: Medical colleges must strictly adhere to the minimum standards prescribed by the Central Council for Indian Medicine for each academic year. They cannot assume that permission for a later year will validate admissions for an earlier year with deficiencies.

Q: What are the implications of this judgment for students?

A: Students should ensure that the medical college they are seeking admission in has the necessary permissions and meets the prescribed standards for the relevant academic year. If the college does not have the required permissions, the medical qualification granted to the student may not be recognized.

Q: What was the role of the 2016 Regulations in this case?

A: The 2016 Regulations, which superseded the 2012 regulations, mandated that institutions possess a Central Research Laboratory and an Animal House. These regulations also specified that institutions must meet minimum infrastructure and teaching standards by December 31 of each year to be considered for permission for the following academic year.

Q: What case did the Supreme Court rely on in its judgment?

A: The Supreme Court relied on its previous judgment in Ayurved Shastra Seva Mandal and Another v. Union of India and Others, which held that deficiencies in one academic year cannot be cured by compliance in a subsequent year.