Supreme Court Upholds NEET Admission Schedule: Maharishi Markandeshwar University Case (2017)

Date of the Judgment: 19th June 2017

Citation: Not available in the provided document.

Judges: Hon’ble Dr. Justice D.Y. Chandrachud and Hon’ble Mr. Justice Sanjay Kishan Kaul (Vacation Bench)

Can medical colleges bypass the established admission timelines for postgraduate courses? The Supreme Court of India, in this case, addressed an application by Maharishi Markandeshwar University seeking permission to fill vacant seats after the stipulated deadline. The core issue revolved around maintaining the integrity of the admission schedule set by the Court to ensure standards in medical education. The bench, comprising Justices D.Y. Chandrachud and Sanjay Kishan Kaul, delivered the order.

Case Background

Maharishi Markandeshwar University sought permission to fill 33 vacant seats in MD/MS/PG Diploma courses and 23 seats in MDS courses for the academic year 2017-18. The university wanted to admit students who had qualified in the National Eligibility cum Entrance Test (NEET), irrespective of whether they were pre-registered with the State of Haryana, by June 15, 2017.

The first round of counseling for postgraduate seats in Haryana took place on May 30, 2017, followed by a second round on June 6/7, 2017, and a mop-up round on June 9, 2017.

Timeline

Course of Proceedings

The Supreme Court noted that it had previously established a strict time schedule for completing medical college admissions in the case of Ashish Ranjan and Ors. vs. Union of India & Ors. (2016) 11 SCC 225. The Court had also, on June 13, 2017, in Association of Private Medical and Dental Colleges of Chhattisgarh vs. The State of Chhattisgarh and Ors. declined to grant any further extension of time beyond the schedule prescribed in the Ashish Ranjan case.

Legal Framework

The Supreme Court referred to its previous judgment in Ashish Ranjan and Ors. vs. Union of India & Ors. (2016) 11 SCC 225, which laid down a time schedule for completing admissions to medical colleges. The Court emphasized that this schedule must be strictly followed to maintain standards in medical education.

The Court also cited its order in Association of Private Medical and Dental Colleges of Chhattisgarh vs. The State of Chhattisgarh and Ors., where it had refused to extend the admission deadline, reinforcing the importance of adhering to the Ashish Ranjan schedule.

Arguments

Applicant (Maharishi Markandeshwar University) Submission:

• The university sought permission to fill 33 vacant seats in MD/MS/PG Diploma courses and 23 seats in MDS courses.
• They wanted to admit NEET qualified students, whether pre-registered with the State of Haryana or not, by June 15, 2017.

Court’s Observation:

• The Court noted that the first round of counseling in Haryana took place on May 30, 2017, the second on June 6/7, 2017, and a mop-up round on June 9, 2017.
• The Court highlighted its previous decisions in Ashish Ranjan and Association of Private Medical and Dental Colleges of Chhattisgarh, which emphasized the importance of adhering to the prescribed admission schedule.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was whether to allow Maharishi Markandeshwar University to fill vacant seats after the stipulated deadline, considering the admission schedule laid down in the Ashish Ranjan case.

Treatment of the Issue by the Court

Authorities

The Court considered the following authorities:

Judgment

The Court relied on Ashish Ranjan and Ors. vs. Union of India & Ors. (2016) 11 SCC 225* to emphasize the importance of adhering to the admission schedule for medical colleges. The Court also cited Association of Private Medical and Dental Colleges of Chhattisgarh vs. The State of Chhattisgarh and Ors.* to support its refusal to grant any further extension of time.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily driven by the need to maintain the integrity of the admission schedule for medical colleges. The Court emphasized that any deviation from the schedule would compromise the standards of medical education. The Court also considered the fact that multiple rounds of counseling had already taken place in Haryana, indicating that there was no valid reason to grant an extension.

The Court’s reasoning was based on the following logical steps:

The Court considered the arguments made by the applicant, Maharishi Markandeshwar University, but ultimately rejected them in favor of maintaining the established admission schedule. The Court did not consider any alternative interpretations, as the need to adhere to the schedule was paramount.

The Court stated, “In Ashish Ranjan & Ors. v. Union of Inda & Ors. [WP(C) No. 76/2015], this Court laid down a schedule to be followed for admission to medical colleges.”

The Court further observed, “This schedule, as approved by this Court, must be followed to ensure that medical education standards are not lowered as per the schedule laid down in Ashish Ranjan case (supra).”

The Court concluded, “We are satisfied in the facts of the present case that there is no reason to grant of further extension. Any such extension will breach the time schedule prescribed by this Court in Ashish Ranjan (supra).”

Key Takeaways

• Medical colleges must strictly adhere to the admission schedule prescribed by the Supreme Court.
• No extensions will be granted beyond the stipulated deadlines, even if seats remain vacant.
• The primary objective is to maintain standards in medical education, which requires strict adherence to the admission schedule.

Directions

The Supreme Court dismissed the application by Maharishi Markandeshwar University, thereby upholding the admission schedule.

Development of Law

The ratio decidendi of this case is that the admission schedule prescribed by the Supreme Court in Ashish Ranjan must be strictly adhered to, and no extensions will be granted. This reinforces the Court’s commitment to maintaining standards in medical education through strict adherence to timelines. There is no change in the previous position of law, as the Court is reiterating its earlier stance.

Conclusion

The Supreme Court dismissed the application of Maharishi Markandeshwar University, refusing to grant an extension to the admission schedule for postgraduate medical courses. The Court emphasized the importance of adhering to the schedule laid down in the Ashish Ranjan case to maintain standards in medical education. This decision reinforces the Court’s commitment to ensuring that medical admissions are conducted in a timely and orderly manner.