Supreme Court Upholds MCI Decision on Medical College Deficiencies: Dumka Medical College & Ors. vs. Board of Governors (2021)

Date of the Judgment: 16 February 2021

Citation: (2021) INSC 79

Judges: L. Nageswara Rao, J. and Krishna Murari, J.

Can medical colleges be allowed to operate with severe deficiencies in faculty and infrastructure, jeopardizing the quality of medical education? The Supreme Court of India recently addressed this critical issue, concerning the establishment and renewal of permissions for three medical colleges in Jharkhand. The Court’s decision underscores the importance of maintaining standards in medical education. This judgment was delivered by a two-judge bench comprising Justice L. Nageswara Rao and Justice Krishna Murari.

Case Background

The Government of India, in collaboration with the State of Jharkhand, initiated a plan to establish new medical colleges in three districts: Dumka, Hazaribagh, and Palamu. This initiative was part of a centrally sponsored scheme aimed at enhancing medical education infrastructure. The State of Jharkhand provided essentiality certificates for all three proposed medical colleges. The Medical Council of India (MCI) was tasked with assessing these colleges for the grant of permission to start the MBBS course.

The Dumka Medical College applied for permission on 05 July 2018, seeking to establish a new medical college with an annual intake of 100 students. Following an inspection on 19-20 December 2018, the MCI identified severe deficiencies in faculty, infrastructure, and facilities. Similarly, Hazaribagh and Palamu medical colleges also faced inspections and were found to have significant shortcomings. Despite being given opportunities to rectify these deficiencies, the colleges failed to meet the required standards, leading to the MCI’s decision to deny permission for the establishment of new colleges and renewal of permission for existing ones.

Timeline

Course of Proceedings

Initially, the MCI denied permission to all three medical colleges due to severe deficiencies. The colleges then approached the Supreme Court. The Supreme Court, based on the submissions of the State of Jharkhand that the deficiencies had been rectified, allowed the colleges to participate in the centralized admission process for the academic year 2019-2020. The State of Jharkhand was directed to file an affidavit stating that the deficiencies were rectified and the remaining deficiencies would be removed within three months. However, subsequent inspections by the MCI revealed that the colleges continued to have significant deficiencies, leading to the denial of permission for the academic year 2020-2021.

Legal Framework

The establishment and operation of medical colleges in India are governed by the regulations set by the Medical Council of India (MCI), now succeeded by the National Medical Commission (NMC). These regulations outline the minimum requirements for infrastructure, faculty, and other facilities necessary for providing quality medical education. The MCI conducts inspections to ensure compliance with these standards. The regulations are framed under the powers conferred by the Indian Medical Council Act, 1956. The MCI’s role is to ensure that medical colleges meet the prescribed standards before they are allowed to admit students.

Arguments

Petitioners’ Submissions:

• The petitioners, the medical colleges, argued that they had rectified the deficiencies pointed out by the MCI. They submitted that they had made substantial efforts to improve their infrastructure and facilities.
• They contended that the MCI’s decision to deny permission was not justified, especially after the Supreme Court had allowed them to participate in the admission process for the academic year 2019-2020.
• The students, who were also petitioners, argued that the denial of permission to these colleges would reduce the number of available medical seats in the State, thereby affecting their chances of pursuing medical education.

MCI’s Submissions:

• The MCI argued that the medical colleges had failed to rectify the deficiencies despite being given ample opportunities.
• The MCI submitted that the inspections conducted by them revealed that the colleges lacked essential infrastructure, faculty, and facilities necessary for imparting quality medical education.
• The MCI contended that allowing medical colleges with such deficiencies to operate would compromise the standards of medical education and pose a risk to public health.
• The MCI relied on the inspection reports which showed that the deficiencies were not only in infrastructure but also in the availability of faculty and clinical material.

Issues Framed by the Supreme Court

The Supreme Court considered the following key issues:

1. Whether the Medical Council of India (MCI) was justified in denying permission to establish new medical colleges and renew permissions for existing ones due to significant deficiencies in infrastructure and faculty.
2. Whether the medical colleges had rectified the deficiencies as claimed by them.
3. Whether the denial of permission would affect the chances of students pursuing medical education.

Treatment of the Issue by the Court

Authorities

The judgment does not explicitly cite any specific cases or books. However, it implicitly relies on the regulatory framework established by the Medical Council of India (MCI), now succeeded by the National Medical Commission (NMC), and the Indian Medical Council Act, 1956. The court considered the inspection reports and the MCI’s assessment of the deficiencies in the medical colleges.

Judgment

How each authority was viewed by the Court?

• The Medical Council of India (MCI) Regulations were viewed as the basis for assessing the adequacy of infrastructure and faculty in medical colleges.
• The Inspection Reports of MCI were viewed as factual evidence of the deficiencies in the medical colleges.
• The Indian Medical Council Act, 1956 was viewed as the source of the MCI’s power to maintain standards in medical education.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the need to maintain high standards in medical education. The Court emphasized that the quality of medical education cannot be compromised. The court also took into account the repeated failures of the medical colleges to rectify the deficiencies despite being given multiple opportunities. The court also considered the fact that the State of Jharkhand had not taken adequate steps to ensure that the necessary infrastructure and facilities were in place, despite their undertaking to do so.

The court’s reasoning was based on the factual findings of the MCI’s inspections, which showed that the colleges had not met the required standards. The court also considered the legal framework governing medical education and the importance of ensuring that medical colleges provide quality education. The court rejected the colleges’ claims that they had rectified the deficiencies, as the evidence presented by the MCI showed otherwise.

The Court considered the argument that denying permission would impact the students but prioritized the importance of maintaining standards in medical education. The Court’s reasoning was based on the evidence presented by the MCI, which showed that the colleges had not met the required standards. The Court also considered the legal framework governing medical education and the importance of ensuring that medical colleges provide quality education.

The court did not consider any alternative interpretations, as the factual findings of the MCI’s inspections were clear and unambiguous. The court’s decision was based on the principle that medical colleges must meet the required standards before they are allowed to operate.

The decision was reached by considering all the evidence and legal framework and the court concluded that the MCI was justified in denying permission to the medical colleges.

“Permission granted for admission for the academic year 2019-2020 is based on a statement made on behalf of the State of Jharkhand that the deficiencies pointed out by the MCI have been removed.”

“It is clear that gross deficiencies still exist in spite of the affidavits and undertakings filed on behalf of the State of Jharkhand.”

“Though, some laxity is shown in respect of medical Colleges established by the State Government, permission cannot be granted for allotment of students to Medical Colleges which lack the necessary infrastructure and facilities.”

There was no minority opinion in the judgment. Both the judges agreed with the reasoning and the conclusion.

The Supreme Court’s decision has significant implications for future cases involving the establishment and operation of medical colleges. It reinforces the importance of maintaining standards in medical education and the role of the MCI in ensuring compliance with these standards. The judgment also highlights the responsibility of State Governments to ensure that medical colleges meet the required standards before they are allowed to operate.

No new doctrines or legal principles were introduced in this judgment. The court applied the existing legal framework and principles to the facts of the case.

Key Takeaways

• Medical colleges must strictly adhere to the standards set by the Medical Council of India (MCI) and now National Medical Commission (NMC) regarding infrastructure, faculty, and facilities.
• State Governments have a crucial role in ensuring that medical colleges meet these standards.
• The Supreme Court will not compromise on the quality of medical education and will uphold the decisions of regulatory bodies like the MCI when they are based on factual findings of non-compliance.
• Affidavits and undertakings made before the court must be followed in letter and spirit.

Directions

The State Government is directed to rectify all the deficiencies that have been pointed out by the MCI at the earliest and make an application for renewal of permission for admission of the second batch of MBBS students for the academic year 2021-2022.

Specific Amendments Analysis

There were no specific amendments discussed in the judgment.

Development of Law

The ratio decidendi of this case is that medical colleges must meet the prescribed standards for infrastructure, faculty, and other facilities as set by the Medical Council of India (MCI) and now National Medical Commission (NMC), and that the Supreme Court will uphold the decisions of regulatory bodies when these standards are not met. This judgment reinforces the existing legal position and does not introduce any new legal principles. The Court has not changed its position on the importance of maintaining standards in medical education.

Conclusion

The Supreme Court dismissed the writ petitions filed by the medical colleges and the students, upholding the MCI’s decision to deny permission for the establishment of new medical colleges and renewal of permissions for existing ones. The Court emphasized the importance of maintaining standards in medical education and the need for medical colleges to adhere to the prescribed norms. The State Government was directed to rectify all the deficiencies and make a fresh application for renewal of permission for the academic year 2021-2022.