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Court Orders Additional Seat for Meritorious Candidate in DM Cardiology Course

Background

The case involved a petitioner who had secured the 6th rank in the INI-SS Entrance Test for the July 2024 session, but was denied admission to the DM Cardiology course at the Post Graduate Institute of Medical Education & Research (PGIMER), Chandigarh. This was due to the failure of the All India Institute of Medical Sciences (AIIMS), New Delhi, to advertise an additional seat that had become vacant at PGIMER, Chandigarh, following the resignation of a senior resident doctor.

Arguments

The petitioner argued that PGIMER, Chandigarh had informed AIIMS, New Delhi about the vacant seat, but AIIMS failed to include it in the final seat allocation notice. The petitioner contended that this omission had prejudiced his candidature, as he would have been eligible for the sixth seat had it been advertised.

AIIMS, New Delhi, argued that the resignation was accepted by PGIMER, Chandigarh in March 2024, but the institute had delayed informing AIIMS about the vacancy until May 2024, which was too late to be included in the final seat allocation process.

Court's Analysis and Reasoning

The court acknowledged that the delay in communication from PGIMER, Chandigarh was the primary reason for the vacant seat not being advertised. However, the court noted that the seat had become vacant due to no fault of the petitioner, who had secured a high rank in the entrance test.

The court relied on the principles established in previous Supreme Court judgments, which state that in rare and exceptional cases, a meritorious candidate should not be denied admission due to administrative inefficiency, provided the candidate has approached the court in a timely manner.

Decision

The court directed AIIMS, New Delhi, to promptly add an additional seat and grant the petitioner admission to the DM Cardiology course at PGIMER, Chandigarh, for the July 2024 session. The court emphasized that ensuring all available seats are filled is in the best interest of public health and institutional efficiency, and denying the petitioner this opportunity would be unjust and contrary to the principles of fair competition and merit-based selection.