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2025 Supreme(Ker) 3020

IN THE HIGH COURT OF KERALA AT ERNAKULAM
ANIL K. NARENDRAN, MURALEE KRISHNA S., JJ.
Under Graduate Medical Education Board National Medical Commission – Appellant
Versus 
V.N. Public Health And Education Trust – Respondent
WA NO. 2466 OF 2025
Decided on : 29-10-2025

Advocates Appeared:
For the Appellant : SRI.A.R.L. Sundaresan, ADDL. SOLICITOR GENERAL OF INDIA SHRI.K.S. PRENJITH KUMAR, SC
For the Respondent: SHRI.P. SREEKUMAR (SR.) SHRI.S. GANESH, SC, KERALA UNIVERSITY OF HEALTH
SCIENCES ADV. SRI.S. VINOD BHATT FOR R1 AND R2 SMT.ANAGHA LAKSHMY RAMAN FOR R1 AND R2

The court reaffirmed that compliance with current educational regulations is mandatory for medical institutions, asserting that administrative decisions must adhere to established statutory standards without judicial interference absent jurisdictional errors.

Headnote:(A) National Medical Commission Act, 2019 - Sections 5(i) and 22(3), Maintenance of Standards of Medical Education Regulations, 2023 - Writ appeal challenging reduction of MBBS seats from 150 to 100 by National Medical Commission - Court established authority of academic regulations superseding prior standards - Found issuance of a conditional reduction as arbitrary, upholding the institution's entitlement vital under earlier directives. (Paras 6, 14, 37)

(B) Administrative Law - Writ Jurisdiction - Alternative remedy principle invoked - Court noted non-compliance of legal standards disallowed for arbitrariness under Article 14 of the Constitution - Found necessity for institutions to provide adequate faculty and infrastructure as per statutory norms. (Paras 26, 30, 36)

Facts of the case:
The appellants challenged the Single Judge's order allowing an MBBS intake of 150 students at a medical college following a directive from the Supreme Court for the academic session 2025-26, after reducing the seats for failing to comply with the latest educational regulations.

Findings of Court:
The learned Single Judge’s judgment was set aside; the institution was unable to comply with the new Mandatory Standards upon review which led to legal reprimands in regulatory adherence.

Issues: Whether the reduction was valid under the National Medical Commission Act, and if the interim order was legally permissible without enduring the administrative appeal processes.

Ratio Decidendi: The court ruled that established statutory criteria have precedence in determining MBBS seat allocations, with judicial oversight limited if statutory remedies are available, reinforcing the hierarchy of educational regulations and compliance required from medical institutions.

Result: Writ appeal allowed, judgment of the learned Single Judge set aside.

Table of Content
1. challenge against a single judge's order. (Para 1 , 2 , 3 , 4 , 5 , 6)
2. arguments presented by the appellants and respondents. (Para 8 , 9 , 10 , 11)
3. analysis of regulations and compliance requirements. (Para 12 , 13)
4. contentions regarding compliance with court directives. (Para 20 , 21)
5. precedents regarding medical education standards. (Para 22 , 23 , 24 , 25)
6. public notices and compliance issues with regulations. (Para 26 , 27 , 28)
7. jurisdictional remedies for appeal. (Para 29)
8. efficacious alternative remedies in legal proceedings. (Para 30 , 31 , 32)
9. mandates of medical education regulations. (Para 33 , 34 , 35 , 36)
10. final ruling on the writ appeal. (Para 37)

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 judgment dated 08.10.2025 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 2nd respondent National Medical Commission (2nd 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 1st respondent Under Graduate Medical Education Board (1st 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 (LoP) 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 (1st and 2nd appellants and the 3rd 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 respondents to grant LoP to the petitioners for 150 MBBS seats during the academic session 2025-26; and a writ of mandamus commanding the 3rd respondent Kerala University of Health Sciences to grant order of Continuation of Provisional Affiliation for 150 MBBS seats during the academic session 2025-26.

3. In W.P.(C)No.32178 of 2025, the petitioners sought for an interim order to permit them to admit the second batch of 150 MBBS students during the academic session 2025-26 and to direct the respondents to pass appropriate orders for the purpose thereof, pending disposal of the writ petition. On 25.08.2025, when the writ petition came up for admission as a ‘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 2nd petitioner stating additional facts.

4. By the interim order dated 27.08.2025, the learned Single Judge directed the respondents to permit the petitioners to admit the second batch of 150 MBBS students, during the academic session 2025-26. The 3rd respondent University was directed to pass appropriate orders for that purpose, as early as possible. On 09.09.2025, the petitioners filed I.A.Nos.2 and 3 of 2025 in W.P.(C)No.32178 of 2025. I.A.No.2 of 2025 was filed seeking an order directing the respondents to pass orders in compliance with the interim order dated 27.08.2025, within a time limit to be stipulated by this Court, so as to enable the petitioners to admit 150 students in the second roun

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