Interim relief in educational admissions must not equate to final relief unless justified; compliance with statutory standards is essential for approval.

JUDGMENT :

ANIL K. NARENDRAN, J.

1. The appellants, who are respondents 1 and 2 in W.P.(C)No.32178 of 2025, have filed this writ appeal, invoking the provisions under Section 5(i) of the KERALA HIGH COURT ACT , 1958, challenging the interim order dated 27.08.2025 of the learned Single Judge in that writ petition.

2. W.P.(C)No.32178 of 2025 is one filed by the petitioners (respondents 1 and 2 herein), namely, V.N. Public Health and Educational Trust and its Managing Trustee, seeking a writ of certiorari to quash Ext.P1 order dated 22.08.2025 of the 2^nd respondent National Medical Commission (1^st appellant herein), in the appeal filed by Palakkad Institute of Medical Sciences, Walayar, under Section 22 (3) of the National Medical Commission Act, 2019, read with Section 9 of the Maintenance of Standards of Medical Education Regulations, 2023, and Ext.P13 order dated 14.07.2025 of the 1^st respondent Under Graduate Medical Education Board (1^st appellant herein), whereby the Board decided to reduce 50 seats in Palakkad Institute of Medical Sciences, and granted conditional renewal of only 100 MBBS seats, for the academic session 2025-26; a declaration that for the institutions granted Letter of Permission under the Establishment of Medical College Regulations, 1999, read with the Minimum Standard Requirements for 150 MBBS Admissions Annual Regulations, 1999, and the Minimum Requirements for Annual MBBS Admissions Regulations, 2020, yearly renewals till the grant of Letter of Recognition is governed by said norms; a writ of mandamus commanding the respondents (1^st and 2^nd appellants and the 3^rd respondent University) to permit the petitioners to admit second batch of 150 MBBS students during the academic session 2025-26; a writ of mandamus commanding the appellants to grant Letter of Permission to the petitioners for 150 MBBS seats during the academic session 2025-26; and a writ of mandamus commanding the 3^rd respondent Kerala University of Health Sciences to grant order of Continuation of Provisional Affiliation for150 MBBS seats during the academic session 2025-26.

3. The interim relief sought for in W.P.(C)No.32178 of2025 reads thus:

“For the reasons stated in the accompanying affidavit and in the writ petition, this Hon’ble Court may be pleased to permit the petitioners to admit the second batch of 150 MBBS students during the academic session 2025-26 and further direct the respondents to pass appropriate orders for the purpose thereof, pending disposal of the writ petition (civil).” (underline supplied)

4. On 25.08.2025, when W.P.(C)No.32178 of 2025 came up for admission as ‘today motion’, it was adjourned to 27.08.2025. On 27.08.2025, the petitioners filed I.A.No.1 of 2025 for accepting an affidavit sworn to by the 2^nd petitioner stating additional facts. The learned Single Judge, by the interim order dated 27.08.2025, directed the respondents to permit the petitioners to admit the second batch of 150 MBBS students, during the academic session 2025-26. The 3^rd respondent University is directed to pass appropriate orders for that purpose, as early as possible. The interim order dated 27.08.2025 of the learned Single Judge in W.P.(C)No.32178 of 2025 reads thus;

“The request of the petitioners for renewal of affiliation with enhancement of MBBS seats from 100 to 150 has been declined by the KUHS stating that there are deficiencies. According to the petitioners, there are no deficiencies if assessed under MSR-2020, and the University is finding fault based on MSR-2023.

2. When the petitioners approached the Hon’ble Apex Court with W.P.(C)No.1166 of 2