Functional Assessment over “Both Hands Intact” — A Landmark Shift in Medical Admissions

1. Introduction

The Supreme Court of India’s decision in ANMOL v. UNION OF INDIA (2025 INSC 256) marks a significant turning point in how medical admissions for persons with disabilities (PwD) are handled. In this case, the appellant, Anmol, challenged the denial of admission to an MBBS course on the ground that he did not meet the “both hands intact” guideline under existing National Medical Commission (NMC) regulations. The Judgment underscores the requirement for a functional assessment of a candidate’s abilities, rather than disqualifying them based solely on a quantified disability that might overshadow their actual, practical capabilities.

The parties involved included Anmol (the appellant), the Union of India, and other relevant respondents such as the Government Medical College conducting the disability assessment. The ultimate highlight of the case is the Supreme Court’s unequivocal stance that mechanical adherence to guidelines without considering reasonable accommodations and assistive technologies is contrary to the constitutional mandate and the provisions of the Rights of Persons with Disabilities Act, 2016 (RPwD Act).

2. Summary of the Judgment

Delivering the opinion, the Supreme Court traced Anmol’s case from his distinguished academic record to his appearance for the NEET-UG 2024 Examination under the PwD category. Despite surpassing the relevant OBC-PwD cut-off, Anmol was declared ineligible by disability boards applying a strict reading of the NMC guidelines. However, after referring the matter to a Committee constituted at All India Institute of Medical Sciences (AIIMS), the Court noted divergent opinions — five members found him unfit under the current guidelines, while Dr. Satendra Singh extensively justified how Anmol could complete the MBBS course with accommodations.

In its final decision, the Supreme Court:

Rejected the mechanical interpretation of having “both hands intact.”
Emphasized the necessity for a functional assessment, and not mere reliance on a quantified disability.
Confirmed Anmol’s admission to MBBS against a PwD (OBC) seat at the Government Medical College, Sirohi, Rajasthan.
Directed the National Medical Commission to expedite the revision of its guidelines in order to bring them in line with constitutional standards and the mandate under the RPwD Act.

3. Analysis

3.1 Precedents Cited

The Court’s decision rests on a line of recent landmark rulings clarifying the rights of persons with disabilities in higher education and professional courses:

Omkar Ramchandra Gond v. Union of India (2024 SCC OnLine SC 2860): Underlined that disqualification solely on the basis of quantified disability is impermissible and that the social model of disability must reign over a rigid medical model. It directed the NMC to revise its regulations to reflect “reasonable accommodation” as envisaged under the RPwD Act.
Vikash Kumar v. UPSC (2021) 5 SCC 370: Provided a broader meaning of reasonable accommodation, stressing that it is not restricted to simple assistive devices but entails meeting “individual needs” to ensure full and equal participation in society.
Om Rathod v. Director General of Health Services (2024 SCC OnLine SC 3130): Reinforced the principle that each candidate must be assessed for “functional competence,” rather than an all-encompassing formula that disregards individual abilities.
Vidhi Himmat Katariya v. Union of India (2019) 10 SCC 20: Distinguished from the present line of thinking, because it did not originally include the modern approach to “reasonable accommodation” that these more recent decisions have embraced.

Collectively, these precedents shaped the Court’s focus on functional assessment, inclusive policies, and the principle of reasonable accommodation, culminating in the rejection of the archaic “both hands intact” rule.

3.2 Legal Reasoning

The Judgment’s bedrock is the recognition that a purely “quantified disability” approach is constitutionally flawed:

The Court categorically held that disabling an aspiring student from pursuing medical studies simply because of a set numeric threshold disregards individual potential. This approach is called overbroad, since it applies a one-size-fits-all plan to vastly different people.
It highlighted that the “both hands intact” requirement is incompatible with Article 41 of the Constitution, the United Nations Convention on the Rights of Persons with Disabilities, and the RPwD Act, all of which aim for inclusive education and respect for human diversity.
The Court endorsed the concept of reasonable accommodation, urging disability assessment boards to actively explore what changes or assistive measures could enable a person with disability to pursue the course. The boards were warned not to become “monotonous automations” that disqualify candidates based solely on disability percentages.
The Justices also stressed the necessity of recording reasons and undertaking a thorough functional analysis. Without concrete, individualized reasons, the board’s negative assessment falls short of legal standards.

3.3 Impact

The decision carries wide-ranging implications:

Revising Medical Admission Guidelines: The National Medical Commission has been directed to file an affidavit and update its admission criteria for PwDs well before the next academic cycle. The new guidelines are expected to move from oversimplified “unfit if over x% disability” rules to a flexible framework grounded in functional assessment and effective accommodations.
Empowering Aspirants with Disabilities: Aspiring doctors with disabilities can no longer be summarily excluded. Functional assessments must be individualized, focusing on real-life tasks and acknowledging the support that assistive devices and technology can offer.
Broadening Inclusive Education Discourses: This ruling underscores that the principle of reasonable accommodation is constitutionally guaranteed, symbolizing a decisive step toward bridging the gap between principle and practice in educational policies for persons with disabilities.
Jurisprudential Shift: The Court’s rejection of “ableist” wording in the regulations cements a progressive judicial outlook that squares fully with the letter and spirit of the RPwD Act and global disability rights norms.

4. Complex Concepts Simplified

Reasonable Accommodation: This term, essential to disability law, means all necessary changes or adjustments to help a PwD participate equally without undue hardship to authorities. It covers anything from modified exam methods and assistive devices to architectural or pedagogical adaptations.

Functional Assessment: Rather than disqualifying a candidate due to a broad medical classification or numeric threshold of disability, functional assessment examines the practical impact of that disability on the candidate’s ability to perform essential tasks. The question becomes: Can, with support, this person effectively fulfill the learning objectives or job duties?

Ableism: A form of discrimination or prejudice against individuals with disabilities. In legal contexts, ableism can manifest as criteria or rules that assume a typical body or mind as the norm, neglecting the idea that diverse abilities, technology, training, and accommodations can achieve the same ends.

Article 41 of the Constitution: A Directive Principle of State Policy urging the government to secure the right to work and education for persons with disabilities within the ambit of its economic capacity and development. While non-justiciable on its own, it is persuasive in interpreting statutes and validating inclusive measures for the welfare of the disabled.

5. Conclusion

The Supreme Court’s pronouncement in ANMOL v. UNION OF INDIA (2025 INSC 256) is unequivocal in affirming that a literal, mechanical reading of disability criteria is no longer tenable. By championing the doctrine of “functional assessment” and by underscoring the need for individualized, reasoned evaluations, the Court has firmly safeguarded constitutional guarantees accorded to persons with disabilities.

In practical terms, future admissions and medical boards must incorporate specific, evidence-based assessments addressing whether a student’s ability to learn or practice medicine is truly hindered if provided with assistive technologies. This strong judicial emphasis on accommodation aligns with both domestic disability legislation and international principles, propelling India’s legal system toward a more inclusive ethos.

Ultimately, the Judgment not only helps Anmol achieve his ambition of becoming a doctor but also lays down a broader framework for protecting the educational rights of persons with disabilities across the country. By doing so, it signals to all institutions — be they legal, medical, or educational — that “ability” is a matter of function, opportunity, and support, rather than a rigid medical checklist.