1. Denial of admission to medical course for person with disabilities based on quantified disability and specific physical requirements under regulatory guidelines. (Para 1 , 2 , 3 , 4 )
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2025 Supreme(SC) 379
SUPREME COURT OF INDIA
B.R. GAVAI, K. V. VISWANATHAN, JJ.
Anmol – Appellant
VERSUS
Union of India & Ors. – Respondents
Civil Appeal No. 14333 of 2024 (@ Special Leave Petition (Civil) No. 27632 of 2024)
Decided On : 21-02-2025
Important Points
The quantified disability alone cannot disqualify a candidate from medical admission; functional assessment and reasonable accommodations are essential for eligibility under the Rights of Persons with Disabilities Act.
Subject
Disability Rights - Education and Admission
Act Referred
CONSTITUTION OF INDIA: Art.14, Art.21
DIRECTIVE PRINCIPLES OF STATE POLICY: Art.41
RIGHTS OF PERSONS WITH DISABILITIES ACT: S.2(h)
DIRECTIVE PRINCIPLES OF STATE POLICY: Art.41
RIGHTS OF PERSONS WITH DISABILITIES ACT: S.2(h)
Headnote
(A) Rights of Persons with Disabilities Act, 2016 - National Medical Commission Guidelines - Admission to MBBS Course - Appellant, a person with disabilities, denied admission based on quantified disability without functional assessment - Court directed admission based on functional assessment and need for reasonable accommodation - Guidelines requiring 'both hands intact' deemed overbroad and discriminatory - Court emphasized the need for a flexible approach to disability assessment. (Paras 1, 9, 12, 21, 44)
(B) Reasonable Accommodation - Concept of reasonable accommodation recognized as a fundamental right - Disability Assessment Boards must assess functional competence rather than solely relying on quantified disability - The approach must be inclusive and not obstructive. (Paras 40, 46)
Facts of the case:
The appellant, with a quantified disability of 58%, was denied admission to the MBBS course despite meeting the cut-off for the OBC-PwD category. The Disability Assessment Board failed to conduct a functional assessment, leading to the dismissal of the appellant's writ petition by the High Court. (Paras 2-5)
Findings of Court:
The Court found the appellant fit for pursuing the MBBS course, emphasizing the need for a functional assessment and reasonable accommodations. The previous denial based on the 'both hands intact' requirement was rejected. (Paras 9, 44)
Issues: The main issues included whether the appellant's quantified disability disqualified him from admission and the validity of the 'both hands intact' requirement in the context of reasonable accommodation. (Paras 21, 44)
Ratio Decidendi: The Court ruled that quantified disability alone cannot disqualify a candidate; a functional assessment is essential to determine eligibility for medical studies, and the existing guidelines must be revised to align with the principles of the RPwD Act. (Paras 21, 44)
Result: Appeal allowed; admission to the MBBS course confirmed. (Paras 47)
(B) Reasonable Accommodation - Concept of reasonable accommodation recognized as a fundamental right - Disability Assessment Boards must assess functional competence rather than solely relying on quantified disability - The approach must be inclusive and not obstructive. (Paras 40, 46)
Facts of the case:
The appellant, with a quantified disability of 58%, was denied admission to the MBBS course despite meeting the cut-off for the OBC-PwD category. The Disability Assessment Board failed to conduct a functional assessment, leading to the dismissal of the appellant's writ petition by the High Court. (Paras 2-5)
Findings of Court:
The Court found the appellant fit for pursuing the MBBS course, emphasizing the need for a functional assessment and reasonable accommodations. The previous denial based on the 'both hands intact' requirement was rejected. (Paras 9, 44)
Issues: The main issues included whether the appellant's quantified disability disqualified him from admission and the validity of the 'both hands intact' requirement in the context of reasonable accommodation. (Paras 21, 44)
Ratio Decidendi: The Court ruled that quantified disability alone cannot disqualify a candidate; a functional assessment is essential to determine eligibility for medical studies, and the existing guidelines must be revised to align with the principles of the RPwD Act. (Paras 21, 44)
Result: Appeal allowed; admission to the MBBS course confirmed. (Paras 47)
Legal Category Hierarchy
- constitutional law
- social welfare law
- administrative law
- education law
Table of Contents
2. Whether eligibility for medical education should be determined by strict adherence to quantified disability guidelines or through individual functional assessment and reasonable accommodation. (Para 4 , 5 )
3. Mechanical interpretation of guidelines and the requirement of intact hands promote ableism and violate the mandate for inclusive education and reasonable accommodation. (Para 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 24 , 25 , 26 , 29 , 30 , 31 , 34 , 35 , 36 , 37 , 38 , 39 , 40 , 41 , 42 , 43 )
4. Eligibility for medical courses must be based on functional competence and reasonable accommodation rather than mere quantification of disability or overbroad physical requirements. (Para 16 , 19 , 22 , 28 )
5. Appeal allowed — High Court order set aside — admission to medical course confirmed — National Medical Commission directed to formulate revised guidelines. (Para 44 , 45 , 46 , 47 , 48 )
6. Can a candidate be disqualified from a medical course solely based on the quantified percentage of their disability?
No. Quantified disability per se does not disentitle a candidate. Eligibility must be determined by whether the candidate can pursue the course, assessed through functional competence and the provision of reasonable accommodations rather than mere quantification. (Para 16 , 22 , 28 )
7. What is the principle of reasonable accommodation under the RPwD Act in the context of professional education?
Reasonable accommodation is a positive obligation to provide necessary modifications and adjustments, without imposing undue burden, to ensure persons with disabilities enjoy rights equally, facilitating their full and effective participation in society. (Para 15 , 19 , 28 )
8. Is a regulatory requirement that both hands must be intact for medical course eligibility legally sustainable?
No. Such overbroad classifications are antithetical to the RPwD Act and Article 41 of the Constitution, as they promote ableism and ignore individual functional assessments of the candidate. (Para 21 , 34 , 35 )
9. What are the obligations of Disability Assessment Boards when evaluating candidates for professional courses?
Boards must not act as monotonous automations. They must conduct functional assessments, record specific reasons for any negative opinion, and determine if the candidate can pursue the course using modern scientific tools and assistive devices. (Para 19 , 22 , 28 )
JUDGMENT
K.V. Viswanathan, J.
1. The present appeal calls in question the correctness of the order dated 23.09.2024 passed by a Division Bench of the High Court of Punjab and Haryana at Chandigarh in CWP No. 24293 of 2024 (O&M). By a short order, the Division Bench rejected the claim of the appellant, a ‘person with disabilities’ and upheld the denial of his admission to the MBBS Course. This Court, by its order dated 12.12.2024, while granting leave, after considering the report of the Medical Board constituted by the All India Institute of Medical Sciences (AIIMS), including the separate opinion of Dr. Satendra Singh, a member of the Board, and considering the legal position directed that the appellant should be admitted in the Government Medical College, Sirohi, Rajasthan against a seat reserved for Persons with Disabilities (PwD) (OBC). By the order of 12.12.2024, the Court had observed that reasons would be separately recorded. The reasons are being recorded by virtue of the present judgment.
Brief Facts:
2. The facts lie in a narrow compass. The appellant had a distinguished academic record in school and passed his 10th grade and 12th grade examination with flying colours. It is clear from the medical opinion of the AIIMS, including the opinion of Dr. Satendra Singh, that the appellant has Locomotor disability 50% with Club foot right lower limb with Phocomalia, Left middle ring finger through middle phalanx with right middle index finger through middle phalanx. Further, he has speech and language disability of 20%. The final disability computed was 58%.
3. The appellant aspired to be a medical professional. The appellant appeared for the NEET-UG 2024 Examination conducted by the National Testing Agency on 05.05.2024. The results were declared and the appellant obtained rank 2462 in the Persons with Disability (PwD) category. The cut-off obtained by him was far above the cut- off for the OBC-PwD Category. The appellant approached the Government Medical College, Chandigarh (Respondent No. 6) - the designated Disability Certification Centre to get his disability assessed.
4. Without assigning any reason whatsoever and without examining the functional disability and merely being carried away by the quantified disability, the Disability Assessment Board, by its Certificate of 02.09.2024, rendered him ineligible to pursue medical course.
5. Aggrieved, the appellant filed Civil Writ Petition No. 24293 of 2024 before the High Court seeking issuance of a Writ of Certiorari to quash the disability certificate and sought a fresh assessment. By the impugned order, the Writ Petition has been dismissed on the ground that the Court cannot substitute the opinion of the experts in the field of disability.
6. When the matter came up before us on 25.11.2024, while issuing notice to the respondents, we passed the following order. The operative portion of which is as follows:
“6. In the meantime, we direct Director, All India Institute of Medical Sciences (AIIMS), New Delhi to constitute a Committee to examine as to whether the disability suffered by the petitioner would come in the way of his pursuing medical studies. We request the Director, AIIMS, New Delhi to co-opt Professor Dr. Satendra Singh as a member of the Committee.
7. The petitioner is directed to remain personally present before the Director, AIIMS, New Delhi on 27.11.2024 at 10.00 A.M.”
7. Thereafter, on 28.11.2024, the report as directed by us, has been furnished. The report is in two parts. Of the total six members, five of the members, except Dr. Satendra Singh, in their brief report observed as under:
“This Medical Board after detailed clinical, radiological, speech and functional assessment of the candidate in the Skills Lab, SET Facility of AIIMS, and as per the NMC Guidelines for candidates with disability opines that the candidate has locomotor and speech related disabilities and belongs to the category of persons with multiple disability. The candidate could perform a few basic
