The eligibility of Foreign Medical Graduates for one-year internships can be determined by verifying their compensatory studies conducted offline, as specified by National Medical Commission guidelines.

JUDGMENT :

Ravi Cheemalapati, J.

Challenging the order dated 28.04.2025 passed by a learned single Judge in Writ Petition vide W.P.No.229 of 2025, the writ petitioner No.13 therein preferred this intra court appeal under clause 15 of Letters Patent.

2. Through the impugned orders the writ petition filed by the petitioner along with others challenging the action of respondent no.1 in not issuing the permanent Registration Certificates/Final Registration Certificate to the petitioners, was dismissed.

3. For convenience, the parties, hereinafter, will be referred to with their status in the writ petition.

4. The contents of the writ petition, in brief, are as follows:

The petitioners have completed five (05) years course of Foreign Medical Graduate Course i.e. Medical Doctor equivalent to MBBS course in India in a foreign country viz., Kyrgyzstan, Philippines and Kazakhstan and accordingly they obtained study certificates from respective universities. They appeared for Foreign Medical Graduate Examination (FMGE) conducted by the National Board of Examination in Medical Sciences and got through the examination. Thereafter, the National Medical Commission (Undergraduate Medical Examination Board) issued circular dated 09.05.2023 giving clarification regarding conduct of internship for Foreign Medical Graduates (FMGs). The petitioners were issued allotment orders permitting them to undergo one year internship programme at the college mentioned in the allotment order and accordingly they underwent internship. But, respondent no.1 refused to issue Permanent Registration Certificates/ Final Registration Certificate even after successful completion of internship. Hence, the writ petition.

5. Respondent no.1 filed counter affidavit denying material averments of the writ petition inter alia contending that respondent no.4-National Medical Council of India (NMC), which is the Regulatory body in respect of Medical Education in the country, has issued public notice pursuant to directions of Hon’ble Supreme Court of India in SLP No.2536-37 of 2022 that the FMGs have to undergo Compulsory Rotating Medical Internship (CRMI) for a period of two years to make up for the clinical training which they could not physically attend during their undergraduate medicine course in the foreign institutions. That thereafter, NMC issued subsequent guidelines on 22.11.2023 and 07.12.2023 stating that the FMGs who studied in online Mode during their final year and penultimate years of their study, have to undergo Two/three years of internship. That as the petitioners have not sufficiently compensated their online study being in India with the offline studies abroad, respondent no.1 has not considered their request to issue Permanent Registrations after completion of one year of internship and they were also instructed to continue their internship for one more year. That the letters of foreign universities that online education was supplemented with offline training do not provide adequate evidence that online learning is equivalent to offline training. That verification of medical degrees through the Indian Embassy/High Commission is under process and the confirmations are also being received in phased manner and permanent registrations will be issued to eligible FMGs as per NMC guidelines after confirming the genuineness of their medical degrees. That only four petitioners filed certificates/confirmation letters, as per which their course was from