Supreme Court Upholds Debarment of Medical College: Ponnaiyah Ramajayam Institute vs. Union of India (22 September 2017)

Introduction

This judgment, Ponnaiyah Ramajayam Institute of Medical Sciences vs. Union of India, was delivered by a bench of the Supreme Court of India comprising Chief Justice Dipak Misra, Justice Amitava Roy, and Justice A.M. Khanwilkar. The judgment was authored by Justice Amitava Roy. The case revolves around the denial of permission to a medical college to admit students for two academic years due to persistent deficiencies.

Case Background

Ponnaiyah Ramajayam Institute of Medical Sciences sought permission to establish a new medical college with an annual intake of 150 MBBS students for the academic year 2016-17. The Medical Council of India (MCI) conducted multiple assessments of the college. These assessments revealed significant deficiencies in infrastructure and clinical facilities. Despite initial conditional permission, the college was eventually debarred from admitting students for the academic years 2017-18 and 2018-19.

The college challenged this debarment. The Supreme Court initially remanded the matter for fresh consideration. However, the Central Government reiterated its decision to debar the college. The college then returned to the Supreme Court, challenging this second order.

Timeline

Course of Proceedings

Initially, the Central Government debarred the college and authorized the MCI to encash the bank guarantee. The college successfully challenged this order in the Supreme Court. The Court remanded the matter for fresh consideration, directing the Central Government to re-evaluate the recommendations of the MCI, Hearing Committee, DGHS, and the Oversight Committee.

Following the remand, the Hearing Committee conducted another hearing. The Central Government then reiterated its decision to debar the college. This led to the college returning to the Supreme Court to challenge the reiterated debarment order.

Legal Framework

The case is governed by Section 10A of the Indian Medical Council Act, 1956, which deals with the permission for establishing a new medical college. The Establishment of Medical College Regulations, 1999, also plays a crucial role. Section 10A(7) outlines the factors to be considered when approving or disapproving a scheme for a new medical college.

Section 10A(7) of the Indian Medical Council Act, 1956 states the factors that must be considered, which include:

• (a) whether the proposed medical college or the existing medical college seeking to open a new or higher course of study or training, would be in a position to offer the minimum standards of medical education as prescribed by the Council under Section 19A or, as the case may be, under Section 20 in the case of postgraduate medical education.
• (b) whether the person seeking to establish a medical college or the existing medical college seeking to open a new or higher course of study or training or to increase its admission capacity has adequate financial resources;
• (c) whether necessary facilities in respect of staff, equipment, accommodation, training and other facilities to ensure proper functioning of the medical college or conducting the new course or study or training or accommodating the increased admission capacity, have been provided or would be provided within the time-limit specified in the scheme;
• (d) whether adequate hospital facilities, having regard to the number of students likely to attend such medical college or course of study or training or as a result of the increased admission capacity, have been provided or would be provided within the time-limit specified in the scheme;
• (e) whether any arrangement has been made or programme drawn to impart proper training to students likely to attend such medical college or course of study or training by persons having the recognised medical qualifications;
• (f) the requirement of manpower in the field of practice of medicine; and
• (g) any other factors as may be prescribed.

Arguments

The petitioner argued that the deficiencies recorded by the Hearing Committee were not valid. They claimed that the college had rectified all deficiencies and should not be debarred. The petitioner contended that the Oversight Committee’s observations supported their claim that there were no disqualifying deficiencies.

The respondents, including the Union of India and the MCI, argued that the college had failed to rectify the deficiencies. They asserted that inspections revealed persistent shortcomings in infrastructure and clinical facilities. They maintained that the decision to debar the college was justified due to the college’s failure to meet the required standards.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was whether the Central Government’s decision to debar the petitioner/college from admitting students for the academic years 2017-18 and 2018-19 and to allow the MCI to encash the bank guarantee was legally sound.

Treatment of the Issue by the Court

Authorities

The Court considered the following authorities:

Judgment

The Supreme Court analyzed the submissions made by both parties and the authorities.

The Court also considered the authorities:

• The Court referred to Modern Dental College and Research Centre and others vs. State of Madhya Pradesh and others* to highlight the role of Oversight Committee.
• The Court referred to Royal Medical Trust (Registered) and Another vs. Union of India and Another* to emphasize the monitoring powers of the MCI and the Central Government under Section 10A of the Act.
• The Court also relied on Royal Medical Trust and Another vs. Union of India and Another* to interpret the purpose of Section 10A of the Act and the Regulations.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the persistent deficiencies in the college’s infrastructure and faculty, as highlighted by multiple inspections. The Court emphasized the importance of maintaining standards in medical education. The factual findings of the MCI and the Hearing Committee weighed heavily in the Court’s reasoning.

The Court’s reasoning was that the college had failed to meet the required standards for medical education. This failure justified the decision to debar the college from admitting students. The Court also noted that it was not equipped to substitute the findings of experts on such issues.

The Court considered the college’s arguments but found them insufficient to overturn the decision. The Court emphasized that the respondents were the best judges to assess the findings of the inspection reports. The Court quoted, “In any view of the matter, the respondents are the best judge to assess the findings in the inspection reports cumulatively on the touchstone of the statutory imperatives to ensure the required standard of medical education and achieve the paramount and salutary objective of the desired quality of health facilities in the public sector.”

The Court also stated, “In a way, a court is ill equipped for want of judicially manageable parameters to substitute the findings of experts on such issue by its views, which otherwise is inexpedient as well.”

The Court further noted, “Thus, in exercise of power of judicial review, re-appreciation of the materials on record, as otherwise warranted by an appellate forum is both inexpedient and uncalled for.”

Key Takeaways

• Medical colleges must adhere to the standards set by the MCI to avoid debarment.
• Persistent deficiencies in infrastructure and faculty can lead to the denial of permission to admit students.
• The Central Government and the MCI have the authority to enforce these standards.
• Judicial review of such decisions is limited, and courts will generally defer to the expertise of the MCI and the Central Government.

Directions

The Supreme Court directed that the college’s application for the academic year 2017-18 would be treated as one for 2018-19. The college was required to keep the bank guarantee deposited with the MCI alive, and the MCI was not allowed to encash it. The MCI was directed to conduct a fresh inspection within three months and apprise the college of the results. If deficiencies were found, the college would be given an opportunity to remedy them. The students admitted for the academic year 2016-17 were allowed to continue their studies until completion of the course.

Development of Law

The ratio decidendi of this case is that medical colleges must strictly adhere to the standards prescribed by the MCI. Persistent deficiencies in infrastructure and faculty can lead to debarment from admitting students. The Court upheld the principle that the MCI and the Central Government are the best judges to assess compliance with these standards. There was no change in the previous position of law, but this case reinforces the existing legal framework.

Conclusion

In conclusion, the Supreme Court upheld the decision to debar Ponnaiyah Ramajayam Institute of Medical Sciences from admitting students for two academic years. The Court emphasized the importance of maintaining standards in medical education and deferred to the expertise of the MCI and the Central Government in assessing compliance with these standards.