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Kerala High Court: Provisional Medical College Admissions Should Not Be Granted Unless a Cast-Iron Case is Made Out

 

Kerala High Court: Provisional Medical College Admissions Should Not Be Granted Unless a Cast-Iron Case is Made Out

The Kerala High Court has held that orders granting provisional admissions into medical or dental courses must not be issued routinely at the interim stage. A Division Bench consisting of Justices Anil K. Narendran and Muralee Krishna S. emphasized that such relief can be accorded only in exceptional circumstances where the petitioner demonstrates a “cast-iron” case or where the error in the admissions process is so manifest and unanswerable that no other conclusion is possible.

The Court’s observations came in the context of a writ appeal concerning the Palakkad Institute of Medical Sciences, which sought interim permission to admit a second batch of 150 MBBS students for the 2025–26 academic year. The Single Judge had earlier directed the Undergraduate Medical Education Board and the National Medical Commission to permit that second batch. On appeal, the Division Bench scrutinized whether the regulatory authorities’ objections to the college’s preparedness and infrastructure were substantial and whether the college rightly sought to eclipse those concerns by relying on interim relief. The Bench found that the Single Judge had erred in assuming that the deficiencies were belatedly raised, and thereby unjustly compounding the institution’s hardship, without proper evaluation of their nature or impact.

Referring to precedents such as Dental Council of India v. Dr. Hedgewar Smruti Rugna Seva Mandal, Manohar Lal Sharma v. Medical Council of India, and Assistant Collector of Central Excise v. Dunlop India Ltd., the Court reiterated that courts must exercise extreme caution before interfering with regulatory oversight in medical education. It noted that admission of candidates without complete and comprehensive facilities, or before compliance with regulatory norms, risks producing inadequately trained doctors—an outcome detrimental to public health. The Bench concluded that ordering provisional admissions in such cases amounts to effectively granting the relief sought in the writ petition, circumventing the regulatory process.

Accordingly, the High Court allowed the appeal and set aside the interim order permitting the second batch admission. It held that granting provisional admissions without satisfying the high threshold for interim relief would interfere with the regulatory framework and the State’s oversight role in medical education. The decision underlines that courts should not lightly grant interim admissions in professional courses, especially in the medical field, unless the case is so clear and compelling that refusal would cause injustice that cannot be remedied later.

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