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IN THE HIGH COURT OF DELHI
Prateek Jalan, J.
Arman Sindhu - Appellant
Versus
Union of India - Respondent
W.P.(C) 8429 of 2021 & CM Appl. 26090 of 2021
Decided On : 18-08-2021




Judicial discretion in extending eligibility deadlines for medical examinations should be exercised cautiously, respecting established procedures and avoiding arbitrary interventions based on individual circumstances.

Headnote:(A) Constitution of India - Article 226 - Medical Council of India Postgraduate Medical Education Regulations, 2000 - NEET-PG exam eligibility - The petitioner, completing internship late due to COVID-19, sought extension of deadline from 30.09.2021 to 31.10.2021; however, the court found the respondents had already considered pandemic circumstances and set deadlines accordingly - The petitioner’s individual hardship does not warrant judicial intervention in admission process timelines. (Paras 1-22)

(B) Judicial Review - The court noted inherent randomness in cut-off dates for medical examinations, asserting that the duty of the writ court is not to disrupt established procedures unless they are arbitrary or unreasonable. (Paras 10, 15, 16, 20)

Facts of the case:
The petitioner is a doctor who completed MBBS and seeks to extend his internship deadline to be eligible for the NEET-PG examination. He will complete his internship after the fixed date due to delays caused by the COVID-19 pandemic.

Findings of Court:
The court held that individual grievances cannot prompt interference in established academic timelines, which are broadly applicable and necessary for orderly administration of examination processes.

Issues: The court addressed whether the existing deadline for internship completion could be extended for the petitioner due to pandemic-related delays.

Ratio Decidendi: The court emphasized respecting institutional deadlines established by authorities and highlighted the importance of procedural consistency in academic settings, rejecting the notion of arbitrary relief for individual circumstances.

Result: Writ petition dismissed.

Table of Content
1. petitioner seeks extension of internship completion date. (Para 1)
2. arguments presented regarding pandemic impact on exam schedule. (Para 2 , 10)
3. regulatory timeline adaptations noted due to covid-19. (Para 3 , 4 , 5 , 6 , 7)
4. petition seeks multiple writs for extending deadlines. (Para 8)
5. government agencies respond to petition. (Para 9)
6. precedent judgments referenced against petitioner's claim. (Para 11 , 12 , 14 , 15 , 19)
7. court emphasizes limits of judicial intervention in academic timelines. (Para 16 , 18)
8. agreement with madras high court’s decision regarding cut-off dates. (Para 20)
9. writ petition dismissed without costs. (Para 21 , 22)

JUDGMENT

1. The petitioner is a doctor. He has completed the MBBS course from Rohilkhand Medical College, Bareilly, Uttar Pradesh and wishes to pursue a post graduate degree. The grievance with which he has approached the Court is that the respondents have fixed 30.09.2021 as the last date for completion of the compulsory one-year rotational internship to enable a candidate to participate in the National Eligibility cum Entrance Test (Post Graduate) [hereinafter, "NEETPG"] examination to be held on 11.09.2021. The petitioner will complete his internship only on 25.10.2021, and therefore seeks a direction upon the respondents to extend the date of completion of internship from 30.09.2021 to 31.10.2021.

2. Mr. Sanjay Sharawat, learned counsel for the petitioner, submitted that this year, due to circumstances arising out of the Coronavirus pandemic, the NEET-PG examination, which is normally held in the month of January, has been postponed to 11.09.2021. According to him, the schedule laid down by the respondents is entirely consistent with completion of the internship by 31.10.2021 or even later. He submits that such a modification would not disturb the proposed schedule, and would enure to the benefit of several candidates whose internship will not be completed by 30.09.2021, but soon after.

3. In support of this contention, Mr. Sharawat drew my attention to the Medical Council of India Postgraduate Medical Education Regulations, 2000 [hereinafter, "PGMER"] wherein the schedule for completion of the admission process for post graduate medical courses has been laid down. This schedule provides that the entrance examination be conducted by 10th January and result be declared by the end of January. Counselling is to be conducted in three rounds between 12th March and 8th May, with 31st May being the last date of joining. In conjunction with this schedule, Mr. Sharawat submitted that the last date for completion of internship for the purposes of eligibility for writing the NEET-PG examination is fixed as 31.03.2021.

4. In the wake of the Coronavirus pandemic, by a notification dated 07.04.2020, the Medical Council of India, now the National Medical Commission [respondent no. 2 herein] [hereinafter, "NMC"], extended the last date for completion of internship to 30.04.2021.

5. By a notice dated 23.02.2021, the National Board of Examinations [hereinafter, "NBE"] [respondent no 3 herein] fixed the NEET-PG examination for 18.04.2021 and the results were to be declared on 31.05.2021. At this time, the NBE also issued an examination information bulletin, in which it was provided that the last date for completion of internship was extended to 30.06.2021.

6. Due to the intervening outbreak of the second wave of COVID-19 pandemic in the country, the examination was not held on 18.04.2021. The Ministry of Health and Family Welfare, Government of India issued a letter dated 03.05.2021 to the State Governments stating that the NEET-PG examination was being postponed and would not be held prior to 31.08.2021. The aforesaid letter also called upon the States to utilize prospective NEET-PG candidates in the COVID-19 workforce. According to the petitioner, he has also been serving in COVID-19 related duties since April, 2021.

7. The NEET-PG examination has now been

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