Delhi High Court Upholds Medical Board’s Denial of MBBS Admission to PwD Candidate, Emphasizing Patient Safety and Competency Standards; Urges NMC to Explore Inclusive Pathways

Court’s Decision:
The Delhi High Court dismissed the appeal challenging the decision of medical boards which deemed the appellant, a candidate with benchmark disabilities, ineligible for pursuing an MBBS degree. The court emphasized that, based on expert opinions, the candidate’s disabilities would prevent him from acquiring essential medical skills necessary for patient care. The court further noted that it cannot substitute its own view over the expert opinions provided by qualified professionals in medical assessment boards.

Facts:
The appellant, diagnosed with a 42% disability due to congenital absence of multiple fingers and toes, qualified for admission under the SC-PwD category for NEET 2024. Upon seeking the mandatory Disability Certificate for NEET admissions, he was evaluated by the designated Vardhman Mahavir Medical College-Safdarjung Hospital. While his disability was assessed within the permissible range, the hospital concluded that his disabilities disqualified him from pursuing a medical course due to upper limb limitations. The appellant subsequently petitioned for reassessment and potential admission to the MBBS program, arguing that his disability should not bar him from realizing his ambition to become a doctor.

Issues:
The primary issue was whether the appellant’s disability, specifically his limited motor function in both hands, rendered him ineligible for admission to the MBBS course under current regulations, given the physical demands and patient safety considerations intrinsic to medical training.

Petitioner’s Arguments:
The appellant argued that the disability assessment failed to account for “reasonable accommodation” and assistive devices as mandated by the Rights of Persons with Disabilities (RPwD) Act, 2016. He contended that the medical boards did not comprehensively evaluate his functional capacity with these aids, and that his disability should not automatically exclude him from medical education. Citing international examples and legal precedents, he asserted that individuals with similar disabilities have successfully pursued careers in medicine.

Respondent’s Arguments:
The National Medical Commission (NMC) argued that both hands’ full function is essential for medical training, and limitations in motor skills could jeopardize patient care. The respondent highlighted that the candidate’s disabilities would prevent him from fulfilling key skills required of MBBS graduates, as certified by multiple medical boards. The respondent further noted that alternative paths, such as a teaching role within medicine, still required an MBBS qualification, which the candidate was unfit to pursue.

Analysis of the Law:
The court scrutinized the RPwD Act, 2016, and applicable regulations which require institutions to reasonably accommodate disabled candidates. However, it observed that such accommodations must align with public safety and educational competence standards in fields like medicine. The court acknowledged the appellant’s right to equal opportunity but underscored that this right must be balanced with patient welfare concerns integral to medical training.

Precedent Analysis:
Citing Vidhi Himmat Kataria v. State of Gujarat and recent Supreme Court judgment Omkar Ramchandra Gond v. Union of India, the court reiterated that judicial review cannot substitute expert medical opinion where detailed, reasoned reports confirm that a candidate’s disability precludes the necessary competencies for patient safety.

Court’s Reasoning:
The court found that the reports by medical boards conducted under judicial oversight adequately explained the reasons for the appellant’s ineligibility. The boards consistently concluded that the appellant’s motor limitations would impede his ability to meet the MBBS program’s core competencies, particularly in surgical and emergency settings.

Conclusion:
The court upheld the findings of the medical boards and dismissed the appeal. It emphasized the limitations of judicial intervention in expert assessments, especially when public safety and patient care standards are at stake. However, the court encouraged the NMC to explore pathways for disabled candidates within medical fields, ensuring inclusion where feasible.

Implications:
This judgment underscores the high standards set for physical competencies in medical education, balancing inclusivity with patient safety. The court’s direction to the NMC to revisit policies for disabled candidates may prompt reforms, enabling broader participation in non-clinical medical roles without compromising critical standards.

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