1. Court’s Decision
The Supreme Court ruled in favor of the appellant and set aside the decision of the High Court, which had upheld the medical board’s denial of admission. The Court held that:
- The rejection of the appellant’s admission based on a mechanical application of disability guidelines was discriminatory.
- The requirement of having “both hands intact” to pursue MBBS was ableist, outdated, and contrary to the Rights of Persons with Disabilities (RPwD) Act, 2016.
- Disability assessment boards must conduct a functional assessment rather than rejecting candidates solely based on quantified disability percentages.
- The concept of reasonable accommodation should be applied, and assistive technologies must be considered.
- The National Medical Commission (NMC) must revise its guidelines to ensure a more inclusive approach to disability assessment.
The Court confirmed the appellant’s admission to the MBBS program and set a date for reviewing the NMC’s compliance with its directions.
2. Facts of the Case
- The appellant, a high-achieving student, was diagnosed with multiple disabilities, including 58% locomotor disability (affecting hand movement and dexterity) and 20% speech and language impairment.
- He cleared NEET-UG 2024 and secured a rank of 2462 in the PwD category, well above the cut-off for the OBC-PwD reservation.
- Seeking admission under the Persons with Disabilities quota, he approached the Disability Assessment Board at Government Medical College, Chandigarh for evaluation.
- The Board declared him ineligible for MBBS based on a strict interpretation of the National Medical Commission (NMC) guidelines, which required candidates to have “both hands intact with intact sensations, sufficient strength, and range of motion.”
- The High Court dismissed the appellant’s plea, stating that courts could not substitute expert opinions.
The appellant then approached the Supreme Court, which ordered a fresh medical evaluation at AIIMS, New Delhi.
3. Issues Before the Court
- Whether the rejection of the appellant’s admission violated his fundamental rights under the Constitution and the RPwD Act, 2016.
- Whether disability assessment boards should conduct functional assessments instead of rigidly applying disability percentage thresholds.
- Whether courts have the authority to intervene in expert medical decisions.
- Whether reasonable accommodation should be a decisive factor in determining eligibility for MBBS admission.
4. Arguments by the Appellant (Petitioner)
- Violation of Disability Rights: The rejection was discriminatory as his disability percentage fell within the eligible range for medical admissions under the PwD quota.
- Outdated and Ableist Guidelines: The requirement for “both hands intact” ignored advancements in assistive technology and accommodations, violating the principles of reasonable accommodation under the RPwD Act, 2016.
- Functional Competency Over Disability Percentages: The appellant argued that his disability did not impair his ability to perform essential medical tasks with the aid of assistive devices.
- Flawed Assessment Process: The Disability Board did not assess his functional abilities, but instead mechanically applied outdated guidelines.
- High Court’s Error: The High Court failed to evaluate whether the Board’s decision violated constitutional principles, merely deferring to expert opinion.
5. Arguments by the Respondents
- Strict Application of NMC Guidelines: The Board followed the guidelines, which explicitly required intact hands for MBBS eligibility.
- Concerns Over Functional Limitations: The respondents argued that the appellant’s disability might affect his ability to handle medical instruments and perform surgical procedures.
- Courts Should Not Interfere in Expert Decisions: They contended that only medical experts should determine eligibility, not courts.
6. Analysis of the Law
The Supreme Court examined the constitutional and statutory framework governing disability rights, including:
A. Rights of Persons with Disabilities (RPwD) Act, 2016
- Mandates inclusive education (Section 16).
- Recognizes reasonable accommodation (Section 2(y)).
- Requires non-discrimination in higher education (Section 32).
B. Constitution of India
- Article 14 (Equality Before Law): The Court ruled that rigid disability guidelines created an overbroad classification that violated the right to equality.
- Article 21 (Right to Life and Dignity): The rejection denied the appellant his right to pursue his chosen career without valid justification.
- Article 41 (Right to Work and Education for Disabled Persons): The State has a duty to ensure opportunities for persons with disabilities to access education and employment.
7. Precedent Analysis
The Supreme Court cited multiple precedents on disability rights:
(i) Omkar Ramchandra Gond v. Union of India (2024)
- Held that disability assessment boards must conduct functional evaluations instead of rejecting candidates based on quantified disability percentages.
(ii) Om Rathod v. Director General of Health Services (2024)
- Invalidated the “both hands intact” requirement, ruling that it was overbroad, ableist, and violated fundamental rights.
- Directed the NMC to revise its guidelines in accordance with disability rights principles.
(iii) Vikash Kumar v. UPSC (2021)
- Established “reasonable accommodation” as a fundamental right under Article 21.
8. Court’s Reasoning
The Supreme Court rejected the AIIMS Board’s majority report and accepted the dissenting report of Dr. Satendra Singh, which emphasized:
- Functional competency should be assessed, not just disability percentage.
- Modern assistive technologies enable persons with disabilities to pursue medical careers.
- Presuming incompetence at the threshold violates the principle of reasonable accommodation.
The Court criticized the NMC guidelines, stating:
- The “both hands intact” rule is unconstitutional, arbitrary, and discriminatory.
- Medical colleges must provide necessary accommodations for PwD candidates.
- Denying admission solely based on outdated guidelines promotes “ableism.”
9. Conclusion
- The Supreme Court confirmed the appellant’s admission to Government Medical College, Sirohi.
- The High Court’s order was set aside.
- The National Medical Commission (NMC) was directed to revise its guidelines in compliance with constitutional and disability rights principles.
- The case was scheduled for further review on March 3, 2025, to ensure compliance by the NMC.
10. Implications of the Judgment
(A) Legal Impact
Establishes functional assessment as the primary eligibility criterion for PwD candidates.
Strengthens the right to reasonable accommodation in professional education.
Sets a binding precedent for future medical admission cases involving disability rights.
(B) Policy Reforms
Forces the NMC to revise outdated eligibility guidelines.
Promotes inclusivity in medical education and other professional courses.
Ensures better training for Disability Assessment Boards to evaluate candidates holistically.
(C) Social Impact
Breaks stereotypes about disabled professionals.
Encourages more PwD candidates to pursue medical careers.
Shifts focus from “disability” to “ability with accommodation.”