Delhi High Court Upholds Strict Compliance with Online Application Procedures and Deadlines in Establishing Medical Colleges

Introduction

The case of SRI SATYA SAI UNIVERSITY OF TECHNOLOGY AND MEDICAL SCIENCES SEHORE v. UNION OF INDIA & ANR., reported as (2023 DHC 5749), adjudicated by the Delhi High Court on August 14, 2023, revolves around the petitioner’s attempt to establish a new medical college for the academic year 2023-24. Sri Satya Sai University of Technology and Medical Sciences Sehore (hereafter referred to as the petitioner), a private institution managed by the Ayushmati Education and Social Society, sought recognition from the Medical Assessment & Rating Board (MARB) under the National Medical Commission (NMC) Act, 2019. The petitioner applied online as per the public notice issued by MARB but faced technical issues that led to the submission of a hard copy of the application. The petitioner contended that this should suffice for consideration. However, the authorities dismissed the application, prompting the petitioner to challenge the dismissal through various appeals and ultimately a writ petition under Article 226 of the Constitution of India.

Summary of the Judgment

The Delhi High Court, presided over by Hon'ble Mr. Justice Purushaindra Kumar Kaurav, thoroughly examined the petitioner’s claims and the responses from the Union of India and MARB. The court reaffirmed the authority of MARB to strictly adhere to the prescribed application procedures and deadlines as laid out in the NMC Act, 2019. The petitioner’s hard copy submission was deemed non-compliant since the public notice explicitly mandated online submissions only. The court dissected various Supreme Court precedents that emphasize the sanctity of procedural adherence in educational admissions. Consequently, the High Court dismissed the petition, upholding the decisions of MARB and the appellate authorities.

Analysis

Precedents Cited

The judgment extensively referenced Supreme Court decisions that underscore the importance of adhering to established time schedules and application procedures in educational institutions. Notably, cases such as Royal Medical Trust v. Union of India, State of Uttar Pradesh v. Dr. Anupam Gupta, and Priya Gupta v. State of Chhattisgarh were pivotal in shaping the court’s stance. These cases collectively emphasize that deviations from prescribed schedules and procedures can lead to arbitrary decisions, thereby undermining the principles of fairness and equality in admissions.

Legal Reasoning

The court’s legal reasoning hinged on the explicit provisions of the NMC Act, 2019, and the accompanying regulations. Section 28 of the Act clearly states that applications for establishing new medical colleges must be submitted in the manner specified by the regulations, which in this case, was exclusively online. The petitioner’s failure to receive an acknowledgment of the online application did not obligate MARB to accept a hard copy, as there was no provision allowing for such exceptions. The court further reasoned that allowing deviations based on technical glitches could set a precarious precedent, leading to potential exploitation and undermining the integrity of the application process.

Impact

This judgment reinforces the necessity for institutions to meticulously follow prescribed application procedures and deadlines. By upholding the exclusive acceptance of online applications as stipulated, the court ensures transparency and uniformity in the establishment of medical colleges. Future applicants are hereby cautioned to adhere strictly to the outlined procedures, and regulatory bodies like MARB are empowered to enforce these norms without leniency, thereby maintaining high standards in medical education.

Complex Concepts Simplified

Several legal and procedural concepts within this judgment merit simplification for better comprehension:

Article 226 of the Constitution of India: Grants High Courts the power to issue writs for the enforcement of fundamental rights and for any other purpose, thereby allowing individuals to challenge administrative actions.
National Medical Commission (NMC) Act, 2019: A legislative framework governing medical education in India, establishing bodies like MARB to oversee the establishment and regulation of medical colleges.
Medical Assessment & Rating Board (MARB): An autonomous body under the NMC responsible for evaluating and granting permissions for the establishment of new medical colleges.
Strict Compliance: The principle that regulations and procedures must be followed exactly as prescribed, without deviations unless explicitly allowed.

Conclusion

The Delhi High Court’s judgment in SRI SATYA SAI UNIVERSITY OF TECHNOLOGY AND MEDICAL SCIENCES SEHORE v. UNION OF INDIA & ANR. serves as a stern reminder of the imperative to adhere strictly to regulatory procedures and deadlines in the domain of medical education. By dismissing the petitioner’s case due to non-compliance with the specified online submission process, the court upholds the integrity and standardization of medical college establishments. This decision not only reinforces the authority of regulatory bodies like MARB but also safeguards the principles of fairness and equality in the admission processes of professional educational institutions.