Introduction

The Supreme Court of India, in the landmark case Shikhar And Another v. National Board Of Examination And Others (2022 INSC 389), addressed the grievances of medical aspirants challenging the deadline set for the completion of internships required for appearing in the National Eligibility cum Entrance Test for Postgraduate (NEET-PG) 2022. The petitioners, comprising doctors preparing for NEET-PG 2022, contended that the extension of the internship completion deadline from May to July 2022 remained inadequate due to delays caused by COVID-19 related deployments in various states. The core issue revolved around whether the Supreme Court should intervene in the regulatory domain to further extend the internship deadline or modify the eligibility criteria in light of the pandemic-induced disruptions.

Summary of the Judgment

The Supreme Court dismissed the petition challenging the extension of the internship completion deadline to July 31, 2022. The Court held that setting such cut-off dates falls under the executive and regulatory authorities' purview, emphasizing judicial restraint in matters of academic policies and administrative regulations. The Court acknowledged the hardships faced by some students but determined that further extension would disrupt the examination schedule and adversely affect other candidates who complied with the revised deadline. Additionally, alternative requests to count COVID-19 duty periods towards internship requirements were declined, as this would entail judicial overreach into curricular matters best handled by academic institutions.

Analysis

Precedents Cited

The judgment extensively referenced prior Supreme Court pronouncements to reinforce its stance on judicial restraint in academic and policy matters:

• Indian Institute of Technology Kharagpur v. Soutrik Sarangi (2021): A three-judge bench emphasized that courts should be circumspect in reviewing academic policies, including admission criteria, and refrain from substituting their judgment for expert bodies.
• All India Council for Technical Education v. Surinder Kumar Dhawan (2009) 11 SCC 726: This case underscored that judicial interference in educational standards and policies should be minimal unless policies are plainly arbitrary or discriminatory.
• State of Bihar v. Ramjee Prasad (1990) 3 SCC 368: The Court held that setting cut-off dates is within the regulatory authority's discretion, and such decisions are not arbitrary unless they are unreasonable or capricious.
• Hirandra Kumar v. High Court of Judicature at Allahabad (2020) 17 SCC 401: Reinforced that cut-off dates or age limits are policy decisions and their arbitrary nature must be clearly demonstrated to warrant judicial intervention.
• Rachna v. Union of India (2021) 5 SCC 638: Highlighted that courts should not compel the executive to formulate specific policies to alleviate individual hardships unless constitutional or statutory rights are infringed.
• Poulami Mondal v. All India Institute of Medical Sciences Writ Petition (s) (Civil) No(s). 623 of 2021: Demonstrated the Court's reluctance to delay examinations based on logistical challenges unless public health and safety are directly threatened.

Legal Reasoning

The Court's legal reasoning was anchored in the principle of separation of powers and the judiciary's limited role in policy-making. It recognized that setting internship deadlines and eligibility criteria are functions inherently vested in the executive and regulatory bodies like the National Board of Examination. The Court noted that while acknowledging the pandemic's impact, it must avoid overstepping into administrative domains that require specialized expertise.

Furthermore, the Court differentiated the present case from previous instances where examination postponements were warranted due to extraordinary circumstances like lockdowns. In this scenario, the extension from May to July 2022 was deemed a balanced approach that considered both the students' hardships and the logistical feasibility of conducting examinations without cascading disruptions.

Impact

This judgment reinforces the judiciary's stance on deferring to expert administrative bodies in matters of academic and professional regulations. It sets a precedent that courts will not intervene in policy decisions unless there is clear evidence of arbitrariness or discrimination. For future cases, this means that similar petitions challenging regulatory deadlines or criteria will likely be dismissed unless they can incontrovertibly demonstrate that such policies violate fundamental rights or are manifestly unreasonable.

In the broader legal context, the decision upholds the principle of administrative autonomy, ensuring that specialized bodies retain the authority to make decisions within their expertise without undue judicial interference. This fosters a clear demarcation of roles among different branches of government, contributing to more streamlined and efficient policy implementation.

Complex Concepts Simplified

• Article 32 of the Constitution: Grants individuals the right to move the Supreme Court directly for the enforcement of fundamental rights.
• Judicial Restraint: A principle where courts limit their own power and avoid interference in areas deemed appropriate for the legislative or executive branches.
• Mandamus: A court order compelling a public official or entity to perform a duty they are legally obligated to complete.
• Cut-off Date: A specified deadline set by authorities beyond which certain criteria or conditions must be met to qualify for a particular opportunity or status.
• Eligibility Criteria: Standards or requirements that individuals must meet to qualify for participation in exams, programs, or positions.

In this judgment, the Court emphasized that setting deadlines (cut-off dates) for internship completion is an administrative decision based on regulatory frameworks rather than matters of personal grievance, thereby falling under the expertise of executive bodies rather than the judiciary.

Conclusion

The Supreme Court's judgment in Shikhar And Another v. National Board Of Examination And Others (2022 INSC 389) reaffirms the judiciary's limited role in intervening in administrative and policy-driven decisions, especially within specialized domains like medical education and examination regulations. By upholding the internship completion deadline, the Court underscored the importance of maintaining procedural integrity and scheduling feasibility, even amidst unprecedented challenges like the COVID-19 pandemic.

This decision serves as a crucial reminder that while the judiciary stands as a guardian of constitutional rights, it must exercise restraint and respect the delineated boundaries of administrative authority. As educational and regulatory bodies navigate the complexities introduced by global crises, this judgment provides a legal framework that balances individual hardships with the collective need for orderly and efficient administration.