UDID Prevails Over Re-Quantification: Functional Competency Boards Cannot Dilute PwBD Reservation in MBBS Admissions

Case: Maaz Ahmad v. U.O.I. Thru. Secy. Ministry Of Health And Family Welfare, Nirman Bhawan, New Delhi & Others (Writ-C No. 7585 of 2025)

Court: High Court of Judicature at Allahabad, Lucknow Bench (Neutral Citation: 2025:AHC-LKO:46235)

Coram: Hon’ble Pankaj Bhatia, J.

Date: 07 August 2025

Introduction

This judgment tackles a recurring and nationally significant question in medical admissions: when a candidate has a valid Unique Disability ID (UDID) reflecting a benchmark disability (≥ 40%) under the Rights of Persons with Disabilities Act, 2016 (RPwD Act), can a National Medical Commission (NMC) designated medical board re-quantify that disability below 40% and thereby dislodge the candidate’s statutory right to reservation, even if the candidate is found functionally competent to pursue MBBS?

The petitioner, a PwBD candidate with a UDID showing 70% locomotor disability (issued by the Chief Medical Officer, Bahraich, a certifying authority under Section 57 RPwD Act), qualified NEET-UG 2025 with an All-India PwBD rank of 997. During counseling, he approached a designated assessment center (BHU) which assessed his disability at 31% but simultaneously declared him functionally capable of undertaking MBBS. The counseling brochure required disability certification from designated centers, creating an immediate conflict between the statutory UDID and the center’s re-quantification.

The core issue: whether the benefit of PwBD reservation is governed by the UDID under the RPwD Act and Rules, or can be negated by a lower percentage assessed by an NMC-designated board which is meant to perform functional assessments.

Summary of the Judgment

• The High Court holds that UDID-based certification issued by the competent authority under the RPwD Act and Rules governs entitlement to reservation for PwBD. It cannot be overridden or diluted by any re-assessment of percentage by NMC-designated medical boards.
• NMC-designated boards’ role is confined to evaluating functional competency for pursuing the MBBS course, in line with the Supreme Court’s decision in Om Rathod v. DGHS (2024). They are not authorized to re-quantify disability for the purpose of reservation.
• Since the BHU board found the petitioner functionally competent and the petitioner’s UDID shows 70% disability, the petitioner is entitled to register and avail PwBD reservation in counseling.
• Respondent authorities are directed to ensure the petitioner can upload his candidature for counseling during the extended window (08.08.2025 to 11.08.2025).

Analysis

Precedents Cited and Their Influence

• Om Rathod v. Director General of Health Services & Others, 2024 SCC OnLine SC 3130
  • The Supreme Court reorients disability assessment in medical education from a “medical model” (percentage fixation) to a “social model” centered on functional competence and reasonable accommodation.
  • Key holdings distilled by the High Court:
    • Disability Assessment Boards must focus on functional competence rather than merely quantifying disability; quantification is relevant to reservation and is captured in the UDID (para 54).
    • Boards must issue speaking orders, ensure transparency and fairness, and be trained in functional, human rights-based assessment (paras 53–54, 57).
    • The Supreme Court’s directions apply in rem (para 59(e)), setting a nationwide jurisprudential standard.
  • Practical implication adopted by the High Court: the UDID governs eligibility for reservation; the board’s remit is functional capability for the course, not re-quantification to undercut statutory entitlements.
• Vishal Gupta v. Union of India & Others, WP(C) No. 1093 of 2022
  • Supreme Court noted NMC’s Interim Guidelines dated 19.07.2025 for AY 2025–26 admissions:
    • PwBD candidates must submit a valid UDID and a self-certified affidavit (Schedule-I).
    • Designated boards verify functional competencies, use standardized tools, and issue speaking orders.
  • The High Court aligns with the interim framework: UDID is the threshold document for reservation; boards perform functional verification, not re-quantification.
• Omkar Ramchandra Gond v. Union of India, 2024 SCC OnLine SC 2860
  • The Supreme Court holds that disqualification cannot be based solely on quantified percentage; boards must examine whether the candidate can pursue the course with disability and reasonable accommodation.
  • The High Court relies on this purposive approach: competence-first, not percentage-first.
• Purswani Ashutosh v. Union of India, (2019) 14 SCC 422
  • Medical boards cannot override statutory mandates on disability reservation; their process must reflect rule-of-law principles.
  • The High Court invokes this to emphasize that no administrative committee has primacy over statutory rights and certificates under the RPwD framework.
• Anmol v. Union of India, 2023:RJ-JP:39699-DB (Rajasthan High Court)
  • Emphasized judicial restraint in reviewing expert boards’ findings.
  • The Allahabad High Court acknowledges deference to expertise but clarifies courts must ensure boards comply with the legal standard: post-Om Rathod, the standard is functional competency and adherence to the RPwD statutory scheme, not fresh percentage quantification.

Legal Reasoning Adopted by the Court

The Court’s reasoning is a careful synthesis of the RPwD statutory scheme, recent Supreme Court jurisprudence, and the NMC’s interim procedural framework:

• Statutory primacy of UDID and certification under RPwD:
  • Section 2(r) RPwD defines a “person with benchmark disability” as one with not less than 40% specified disability.
  • Chapter X of the Act and the Rules (as amended in 2024) govern certification and UDID issuance:
    • Rule 17: Application for disability certificate/UDID through the UDID portal to designated medical authority.
    • Rule 18: On verification, the authority issues a disability certificate and a color-banded UDID card (White: <40%; Yellow: 40–<80%; Blue: ≥80%).
    • Rule 19: The certificate/UDID entitles the holder to facilities, concessions, and benefits under Government schemes.
  • Only the authorities recognized under the Act/Rules can quantify disability; other bodies cannot legally displace the UDID’s quantified status for reservation purposes.
• Role demarcation: UDID for reservation; designated boards for functional competency
  • Relying on Om Rathod, the Court draws a clear jurisdictional line:
    • UDID quantification answers whether a candidate is a “PwBD” entitled to reservation benefits.
    • Functional assessment answers whether the candidate can pursue MBBS with or without reasonable accommodation.
  • The High Court finds the NMC practice of re-quantifying the percentage at assessment centers (as happened at BHU) to be inconsistent with the RPwD scheme and the Supreme Court’s binding approach.
• Application to facts
  • The petitioner’s UDID (70% locomotor) establishes benchmark disability for reservation.
  • The BHU board declared him functionally competent for MBBS, which is the only question the board was authorized to answer under the Supreme Court’s jurisprudence.
  • The BHU’s 31% quantification cannot dislodge the UDID’s reservation-qualifying status; hence, the petitioner must be permitted to register and avail reservation.
• Administrative alignment with Supreme Court’s interim framework
  • Referring to the NMC Interim Guidelines (19.07.2025) noted in Vishal Gupta (SC), the Court underscores speaking orders, standardized functional tools, and holistic assessment.
  • It notes that any guidelines allowing re-quantification by boards are at variance with the Supreme Court-accepted interim framework and the RPwD Act.

Impact and Prospective Significance

• Immediate effect for NEET-UG 2025–26:
  • Counseling authorities must accept UDID as the sole basis for PwBD reservation eligibility.
  • Designated boards must limit themselves to functional competency assessments and issue reasoned (speaking) orders.
  • Registration portals and back-end validation must be updated to prevent rejection of UdID-backed PwBD claims based on any board’s re-quantification.
• Standard-setting beyond the case:
  • Recalibrates national practice in line with Om Rathod’s in rem directions: disability is not to be “brought down” for admissions; the social model and functional end-points govern.
  • Expect revision of counseling brochures and NMC circulars to clearly distinguish UDID-based reservation from functional competency assessment.
• Institutional obligations:
  • Medical colleges must prepare to provide reasonable accommodations, maintain Enabling Units as contact points, and build databases on accessibility, as urged by the Supreme Court.
  • Assessment boards must include doctors with disabilities and be trained to conduct human-rights-compliant functional assessments.
• Litigation posture and governance:
  • Courts will continue to defer to expert boards on functional competence but will intervene to enforce the statutory boundary: boards cannot re-quantify disability to negate reservation.
  • If a UDID is outdated or inaccurate, the proper route is re-assessment through the UDID mechanism under the MoSJE/Rule 18—not by NMC boards at the counseling stage.

Complex Concepts Simplified

• Benchmark Disability: Under Section 2(r) RPwD, a person with ≥ 40% specified disability. This threshold determines eligibility for PwBD reservation in admissions.
• UDID (Unique Disability ID): A nationally recognized identity card and certificate issued by competent authorities under the RPwD Rules. It has color bands: White (<40%), Yellow (40–<80%), Blue (≥80%). For reservation, Yellow or Blue suffices.
• Functional Competency Assessment: An evaluation of whether the candidate can perform essential tasks required in the MBBS curriculum and clinical practice, potentially with reasonable accommodation. It focuses on ability to achieve outcomes, not on the manner of achieving them.
• Reasonable Accommodation: Adjustments or support needed to ensure persons with disabilities can enjoy rights on an equal basis (Section 2(y) RPwD). Its denial amounts to discrimination.
• Speaking Orders: Decisions that clearly record reasons and the evidence/criteria considered, ensuring transparency and enabling judicial review.
• In rem effect: A judgment that is intended to have general applicability, not confined to the parties alone. The Supreme Court in Om Rathod declared its directions applicable in rem.
• Designated Medical Boards vs Certifying Authority: Certifying authorities under the RPwD Act/Rules issue UDID and quantify disability. NMC-designated boards verify functional competency for medical education; they do not have legal authority to re-quantify disability for reservation purposes.

Key Compliance Checklist for Stakeholders

• Candidates: Ensure you have a valid UDID (Yellow or Blue band for PwBD reservation). Carry the UDID and prepare to demonstrate functional competencies as per NMC’s Schedule-I affidavit.
• Designated Boards:
  • Do not re-quantify disability for reservation; treat UDID as conclusive for that purpose.
  • Test declared competencies using standardized tools; issue speaking orders.
  • Include a doctor/health professional with disability; ensure accessible and respectful assessment conditions.
• Counseling Authorities (DGHS/State DGME/NMC):
  • Configure portals to accept UDID as decisive for PwBD reservation.
  • Align brochures and notices to distinctively separate “UDID-based reservation eligibility” from “functional competency verification.”
  • Publish institutional accessibility and accommodation data to inform applicants (as urged by the Supreme Court).
• Medical Colleges: Operationalize Enabling Units, plan reasonable accommodations across academics and clinics, and maintain an audit trail for accommodations.

Conclusion

The Allahabad High Court’s decision in Maaz Ahmad strengthens and operationalizes the Supreme Court’s paradigm shift in disability law for medical education. It decisively affirms that:

• UDID certification under the RPwD Act and Rules is the authoritative instrument for determining eligibility for PwBD reservation. Non-statutory re-quantifications cannot override it.
• Designated medical boards must perform only functional competency assessments and issue speaking orders; they are not empowered to re-quantify disability percentages to the detriment of reservation claims.
• This demarcation aligns administrative practice with constitutional values of dignity, equality, non-discrimination, and the RPwD Act’s rights-based framework centered on reasonable accommodation and inclusive education.

Practically, the ruling clears systemic ambiguities that have long disadvantaged PwBD aspirants in medical admissions. By enforcing the UDID’s primacy for reservation and confining boards to functional evaluations, the Court ensures that disability rights move from paper to practice—ushering in admission processes that are both lawful and humane.