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2025 Supreme(Mad) 2784

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.V. KARTHIKEYAN, J.
Dr. Priya Dharshini H. - Petitioner 
Versus
Government of Tamil Nadu, Represented by its Member Secretary, Medical Services Recruitment Board and Ors. – Respondents
W.P.Nos.10628, 10641, 10648, 10661 & 10669 of 2025 And W.M.P.Nos.11955, 11960, 11965, 11983, 11986, 11987, 12007, 12011, 12016, 12023, 12024 & 12025 of 2025
Decided On : 03-04-2025

Advocates Appeared:
For the Petitioners: Mr. M. Velmurugan
For the Respondents:Mr. J. Ravindran, Additional Advocate General Assisted by Mr. L. Murugavelu, Mr. A. Mohamed Goose, Mr. U. Bharanidharan.

Eligibility for recruitment is determined as of the cut-off date specified in the notification; late registrations cannot be accepted as the process must ensure uniformity and fairness.

Headnote:(A) Tamil Nadu Medical Registration Act - Eligibility conditions for medical practitioners - Writ petitions seeking inclusion in selection for Assistant Surgeon (General) rejected as petitioners failed to register with Tamil Nadu Medical Council by cut-off date of 15.07.2024 - The Petitioners completed required qualifications, but registration delays after the cut-off date led to ineligibility. (Paras 6-35)

(B) Eligibility Criteria - The eligibility of candidates for public employment must be assessed on the last date of application submission to maintain uniformity and fairness, as supported by Supreme Court precedents. (Paras 10-30)

Facts of the case:
Petitioners, having completed MBBS and internship, applied for permanent registration post-15.07.2024 due to delays. Arguments indicated technicalities in registration processes led to their exclusion.

Findings of Court:
The court emphasized adherence to the stipulated eligibility criteria and cut-off dates in recruitment notifications, which is binding and cannot be modified arbitrarily.

Issues: Main questions addressed were the eligibility of candidates based on registration timelines and the implications of missed deadlines on recruitment rights.

Ratio Decidendi: The court established that adherence to cut-off dates is crucial in recruitment processes, and eligibility must be determined as per the notification's terms, without exceptions.

Result: Writ petitions dismissed with no order as to costs.

Table of Content
1. overview of petitioners' eligibility and registration process. (Para 2 , 4 , 5)
2. final ruling dismissing the writ petitions. (Para 7 , 8)

ORDER :

(C.V. KARTHIKEYAN, J.)

The writ petitioners had applied for the post of Assistant Surgeon (General).

2. All these Writ Petitions have been filed seeking records relating to the selection list issued consequent to Notification No.01/MRB/2024, dated 15.03.2024 with specific reference to Clause 6B(III) modified by Notification dated 14.05.2024 and to quash the same so far as the non-inclusion of these writ petitioners are concerned.

3. All the writ petitioners have raised the same ground questioning the Notification and therefore, a common order is passed with respect to these writ petitions.

4. All the writ petitioners were duly qualified to apply for the post of Assistant Surgeon (General). They had completed their Bachelor of Medicine and Bachelor of Surgery (M.B.B.S.) degree. Thereafter, they were issued with provisional certificate. Thereafter, they also completed their one year internship programme. On completion of internship, they were issued with provisional certificate-II. After receiving that particular certificate, they had applied with the third respondent for registration as registered Medical Practitioner.

5. The following are the details as to the date on which the petitioners applied for permanent Registration with the Tamil Nadu Medical Council / third respondent and the date on which the approval was granted and the time slot chosen by the writ petitioners and the date on which the certificates were verified for permanent registration.

S. No .W.P.No.PetitionerDate of Application for permanent registrationTNMCTime slot chosen by the petitionerCertificate verification for permanent registration
1.10628 of 2025Dr.Priya Dharshini. H.12.07.2024 10.48 pm13.07.2024 02.50 pm19.07.2024 02.00 pm19.07.2024 01.03 pm
2.10641 of 2025Dr. Sinderla Thangamalar Mary18.07.2024 10.56 am22.07.2024 05.26 pm26.07.2024 11.00 am26.07.2024 11.17 am
3.10648 of 2025Dr.Gayathri.S13.07.2024 12.12 pm13.07.2024 03.19 pm25.07.2024 10.00 am25.07.2024 10.43 am
4.10661 of 2025Dr.Syed Abdul Kareem13.07.2024 05.02 pm14.07.2024 05.42 pm24.07.2024 10.00 am24.07.2024 10.37 am
5.10669 of 2025Dr. Akash C12.07.2024 05.11 pm13.07.2024 01.10 pm16.07.2024 3.00 pm16.07.2024 02.25 pm

6. This Court had occasion to examine similar batch of writ petitions in W.P.No. 6533 of 2025 etc batch [ Dr. M. Sai Ghanesh Vs. Government of Tamil Nadu, represented by its Secretary, Medical Services Recruitment Board, Chennai and others , wherein this Court had passed the following common order:-

“9. The uniform arguments that have been advanced by the learned counsel in all the three Writ Petitions is that the Provisional Certificate -II, which was issued by Dr.M.G.R.Medical University, was issued only on 11.07.2024. It had been contended that these three writ petitioners had completed the course in the College, which runs for about five years in the year 2023 and had been issued with what is called as Provisional Certificate - I. But that is not sufficient. They have to undergo the Internship for a period of one year, which they have successfully completed. The learned counsels pointed out that thereafter, the Provisional Certificate-II had been issued by the University, which was the certificate certifying that they have undergone the course in the College and also successfully completed their Internship as required for a further period of one year. It is uniformly contended that this particular certificate/Provisional Certificate-II was issued only on 11.07.2024. The learned counsels pointed out that all the three writ petitioners had applied for the post of Assistant Surgeon (General) and they were also permitted to write the examinations and that therefore, they had a legitimate expectation that there could be no further hurdles while considering their selection or on examining their credentials vis-a-vis the application

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