1. Review petitions seeking validation of medical degrees and permission to complete studies following a restrictive court judgment. (Para 1 , 2 )
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2025 Supreme(SC) 252
SUPREME COURT OF INDIA
SANJIV KHANNA, SANJAY KUMAR, K.V. VISWANATHAN, JJ.
Dr. Priyambada Sharma, etc. etc. – Petitioner
Versus
Board of Governors In Supersession of Medical Council of India & Ors. etc. – Respondents
Review Petition (Civil) Nos. 1739-1746 of 2023 In Civil Appeal Nos. 7533-7534, 7535, 7536, 7537, 7538, 7539 and 7540 of 2022
Decided On : 28-01-2025
Important Points
The court upheld the validity of degrees awarded to Senior Residents and allowed a student to continue her studies, imposing costs on the authorities for prior hindrance.
Subject
Administrative Law - Educational Law
Headnote
(A) Review of Judgment - The court allowed review petitions concerning degrees awarded to Senior Residents, affirming their validity despite prior judgment dated 17.10.2022. Dr. Priyambada Sharma is permitted to continue her studies after being hindered by the earlier ruling. (Paras 1-3)
(B) Costs - The court imposed consolidated costs of Rs. 5,00,000/- on the University and College, to be deposited in the Chief Minister’s Relief Fund. (Paras 4-6)
(C) Finality of Review - The judgment dated 17.10.2022 is modified as per the current order. (Paras 6-7)
(B) Costs - The court imposed consolidated costs of Rs. 5,00,000/- on the University and College, to be deposited in the Chief Minister’s Relief Fund. (Paras 4-6)
(C) Finality of Review - The judgment dated 17.10.2022 is modified as per the current order. (Paras 6-7)
Legal Category Hierarchy
Advocates appeared:
For the Petitioner(s): Mr. V. Giri, Sr. Adv. Ms. Meenakshi Arora, Sr. Adv. Mr. Sanjay Kumar Singh, Adv. Mr. Abhishek Yadav, Adv. Mr. Vikram Patralekh, Adv. Mr. Braj Kishore Mishra, AOR Mr. B.S. Rajesh Agrajit, Adv. Ms. Jyoti Rana, Adv. Mrs. Meetu Goswami, Adv. Ms. Priya Nagar, Adv. Mr. Siddharth Goswami, Adv. Mr. Shyamal Kumar, AOR
For the Respondent(s): Mr. Subhasish Bhowmick, AOR Ms. Manisha Pandey, Adv. Mr. Rahul Kushwaha, Adv. Mr. Shubhankar, Adv. Mr. M.K. Rathor, Adv. Mr. Reegan S. Bel, Adv. Mr. Pranshu Kaushal, Adv. Mr. Ashutosh Singh, Adv. Mr. Rakesh Kumar Tiwari, Adv. Mr. Gaurav Sharma, Sr. Adv. Mr. Dhawal Mohan, Adv. Mr. Rajesh Raj, Adv. Mr. Paranjay Tripathi, Adv. Mr. Prateek Bhatia, Adv./AOR Mr. Anando Mukherjee, AOR
For the Petitioner(s): Mr. V. Giri, Sr. Adv. Ms. Meenakshi Arora, Sr. Adv. Mr. Sanjay Kumar Singh, Adv. Mr. Abhishek Yadav, Adv. Mr. Vikram Patralekh, Adv. Mr. Braj Kishore Mishra, AOR Mr. B.S. Rajesh Agrajit, Adv. Ms. Jyoti Rana, Adv. Mrs. Meetu Goswami, Adv. Ms. Priya Nagar, Adv. Mr. Siddharth Goswami, Adv. Mr. Shyamal Kumar, AOR
For the Respondent(s): Mr. Subhasish Bhowmick, AOR Ms. Manisha Pandey, Adv. Mr. Rahul Kushwaha, Adv. Mr. Shubhankar, Adv. Mr. M.K. Rathor, Adv. Mr. Reegan S. Bel, Adv. Mr. Pranshu Kaushal, Adv. Mr. Ashutosh Singh, Adv. Mr. Rakesh Kumar Tiwari, Adv. Mr. Gaurav Sharma, Sr. Adv. Mr. Dhawal Mohan, Adv. Mr. Rajesh Raj, Adv. Mr. Paranjay Tripathi, Adv. Mr. Prateek Bhatia, Adv./AOR Mr. Anando Mukherjee, AOR
Table of Contents
2. The court noted the completion of studies and subsequent professional employment for some, and the substantial progress in studies for another. (Para 1 , 3 )
3. Degrees and study continuity may be protected based on peculiar facts and circumstances, such as completion of studies or substantial progress before a restrictive judgment. (Para 1 , 3 )
4. Degrees validated for specific residents, one student permitted to complete studies, and consolidated costs imposed on the university and college. (Para 1 , 3 , 4 , 6 )
5. Can degrees awarded prior to a restrictive court judgment be validated?
Yes, the court may treat degrees as legal and valid if the students completed their studies and were subsequently appointed as Senior Residents, depending on the peculiar facts and circumstances of the case. (Para 1 )
6. Under what circumstances can a student be permitted to complete their studies despite a restrictive judgment?
A student may be permitted to continue and complete their studies if they have already completed a substantial portion of the course before the restrictive judgment was passed. (Para 2 , 3 )
7. Can the court impose costs on educational authorities in review petitions?
Yes, the court may impose consolidated costs on the university and college, to be deposited in a relief fund, as part of the final order. (Para 4 )
ORDER
Having heard the learned counsel for the parties and given the peculiar facts and circumstances of the case, the present review petitions deserve to be allowed to the extent that the review petitioners who have completed their studies in the month of July 2022, and were thereafter appointed and were working as Senior Residents, should not be deprived of their degrees. In other words, the degrees awarded to them, despite the judgment of this Court dated 17.10.2022 passed in the civil appeals, would be treated as legal and valid. This does not include Dr. Priyambada Sharma.
2. As far as Dr. Priyambada Sharma is concerned, it is stated that she had continued with her studies till the judgment dated 17.10.2022 was passed. In view of the said judgment, she was prevented from continuing with her further studies. It is stated that Dr. Priyambada Sharma had taken admission on 17.07.2019.
3. Keeping in view the fact that Dr. Priyambada Sharma already studied for almost three years, we permit her to continue and complete her studies at the North Bengal Medical College, Darjeeling, West Bengal.
4. At the same time, we deem it appropriate to impose consolidated costs of Rs. 5,00,000/- (Rupees five lakhs only) on the authorities concerned, viz., the University and the College, which shall be borne by them jointly and equally, which will be deposited in the Chief Minister’s Relief Fund, Government of West Bengal, within four weeks from the date a copy of this order is received by them.
5. Recording the aforesaid, the review petitions are disposed of.
6. The judgment dated 17.10.2022 shall stand reviewed and modified to the extent indicated above.
7. Pending application(s), if any, shall stand disposed of.
