Introduction

In a significant decision dated April 4, 2025, the Andhra Pradesh High Court, presided by Hon'ble Justice Gannamaneni Ramakrishna Prasad, addressed the issue of reasonable accommodation for a student with a benchmark disability in the context of medical examinations. The petitioner, Jammula Nandasai Mithra, a 22-year-old medico suffering from cerebral palsy, sought additional compensatory time for her MBBS examinations on the grounds that the standard extra time provided was inadequate for her disability.

The petitioner had previously benefited from an interim order in W.P. No. 8781 of 2023, which granted her an extra 30 minutes along with the statutory additional one hour for first-year MBBS examinations. However, when she pursued similar accommodation for the second-year and subsequent examinations, the respondents, including the state health authorities and Dr. NTR University of Health Sciences, declined to extend the benefit. This led to the filing of the present writ petition, challenging the impugned memo and seeking a direction that the extra compensatory time should continue for the entire duration of her MBBS course.

Summary of the Judgment

The High Court’s decision in this case was a carefully balanced one that weighed the petitioner’s right to reasonable accommodation against the test administration guidelines and previous judicial pronouncements. The Court held that:

• The impugned memo restricting the additional time to the first-year MBBS examinations was arbitrary and in violation of the petitioner’s fundamental rights under Articles 14, 19, and 21, as well as the provisions of the Rights of Persons with Disabilities Act, 2016.
• Taking judicial guidance from prior Apex Court decisions, including Vikash Kumar Vs. Union Public Service Commission and Ors. and Syed Bashir-uddin Qadri Vs. Nazir Ahmed Shah, the court recognized the necessity of a “reasonable accommodation” for persons with benchmark disabilities in an equitable academic environment.
• The Court noted that the earlier order in W.P. No. 8781 of 2023—though expressly limited to the petitioner and to the first-year examination context—demonstrated the beneficial effects of extra time on her examination performance and hence could not be arbitrarily restricted to a single academic year.
• Consequently, the Court directed the respondents to extend the additional compensatory time of 30 minutes for the second-year MBBS examinations and for all subsequent examinations until the completion of the petitioner’s course.

Analysis

Precedents Cited

The judgment extensively cites a number of precedents which had a significant influence on the Court’s decision:

• Vikash Kumar Vs. Union Public Service Commission and Ors. (2021): The Apex Court emphasized that failing to meet the individual needs of each differently-abled person breaches the norm of reasonable accommodation. This principle strongly underpinned the petitioner’s argument for a tailored, flexible approach.
• Syed Bashir-uddin Qadri Vs. Nazir Ahmed Shah (2010): This case served to illustrate that persons suffering from cerebral palsy should be accorded special consideration because the disability directly affects their capability to perform in time-bound tasks.
• St. Bhandare Foundation Vs. Union of India (2018): Highlighting that executive action must be relief-oriented rather than obstructive, this precedent reinforced the need for a liberal interpretation of accommodations to benefit disabled persons.
• Other references include judgments such as Gulshan Kumar Vs. Institute of Banking Personnel Selection and Others (2025) and Aveni Frakash Vs. National Testing Agency and Ors. (2023), which together reflect an evolving judicial perspective towards inclusivity and non-discrimination in educational and examination contexts.

Legal Reasoning

The Court’s legal reasoning in the present case hinged on several key points:

• The Principle of Reasonable Accommodation: Anchored in Section 2(y) of the Rights of Persons with Disabilities Act, 2016, the decision underscores that reasonable accommodation involves “necessary and appropriate modifications” that do not impose an undue burden, thereby ensuring equality in the exercise of rights.
• Interpretation of Legislative Intent: The Court drew upon the spirit of the RPwD Act, emphasizing that it is meant to facilitate the integration of disabled persons into mainstream education. The petitioner’s failure to perform without adequate time was recognized as a direct result of her cerebral palsy, warranting an extension of the statutory time provisions.
• Non-binding Nature of Prior Orders: Although the previous order in W.P. No. 8781 of 2023 was explicitly stated as non-precedent for broader application, the Court found that the practical success of that order in enabling the petitioner to pass her first-year examinations could not be overlooked when assessing her ongoing need.
• Issues in Medical Assessment: The judgment also critically examined the composition of the Medical Board that evaluated the petitioner’s disability. It was held that the absence of a neurology expert in the assessment process rendered the evaluation incomplete, further bolstering the petitioner’s claim for continued accommodation.

Potential Impact

The implications of this judgment are multifaceted:

• Policy Reforms in Medical Education: By mandating additional compensatory time across all examinations for students with benchmark disabilities, the Court is likely to prompt medical institutions and regulatory bodies to revise their examination norms. This decision may set in motion more comprehensive policies that ensure disability-inclusive practices.
• Broader Interpretation of “Reasonable Accommodation”: The judgment reinforces the principle that accommodations must be tailored to the specific needs of the individual and not restricted by a rigid application. This is expected to influence similar cases in academic and other competitive examinations.
• Encouragement for Inclusive Judicial Reasoning: Future litigants seeking accommodations under the RPwD Act can rely on the logical framework and precedent-driven approach demonstrated in this decision, potentially enhancing access to justice for disabled individuals.

Complex Concepts Simplified

Several legal concepts in this judgment merit further explanation:

• Benchmark Disability: This term refers to a level of disability recognized under the RPwD Act, which qualifies an individual for specific benefits and accommodations in academic and professional settings.
• Reasonable Accommodation: This legal principle requires institutions to make necessary modifications to ensure that persons with disabilities can participate equally. It is not an absolute entitlement but a flexibly applied measure that considers both the needs of the individual and the resources available.
• Compensatory Time: In the context of examinations, compensatory time is additional time allotted to candidates with disabilities. In this case, the petitioner was initially granted an extra one hour on a three-hour exam duration, supplemented by an additional 30 minutes following judicial intervention.

Conclusion

The judgment in Jammula Nandasai Mithra v. The State of AP represents a transformative moment in the legal landscape concerning the rights of students with benchmark disabilities. By directing that the extra compensatory time be extended to second-year and subsequent MBBS examinations, this decision not only upholds the principles enshrined in the RPwD Act, 2016 but also reinforces the judiciary’s commitment to fostering an inclusive academic environment.

Key takeaways from this judgment include:

• The affirmation that disabled individuals deserve flexible accommodations that adapt to their unique challenges, rather than a one-size-fits-all approach.
• The emphasis on critical judicial evaluation of administrative decisions and medical assessments, ensuring that every individual receives a fair and equitable evaluation.
• A precedent for future cases ensuring that the right to reasonable accommodation is interpreted liberally to promote inclusion in all facets of public life.

This decision is poised to have a lasting impact on academic policies, influencing not only the field of medical education but also serving as a guiding beacon for equality and inclusiveness across all educational institutions.