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2025 Supreme(Online)(Chh) 19918

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ, Bibhu Datta Guru, J
Shri Rawatpura Sarkar Institute Of Medical Science And Research Naya Raipur – Appellant
Versus
State Of Chhattisgarh – Respondent
WPC No. 5989 of 2025

Advocates:
For the Appellants/Petitioners: Ashish Shrivastava, Sangeeta Mishra, Ashutosh Shrivastava, Ishaan Singh Rathore, Shatabdi Bagchi
For the Respondents: Sangharsh Pandey, Anmol Sharma, Ranbir Singh Marhas, Samarth Singh Marhas

The conversion of unfilled NRI quota seats into management quota seats upon expiration of the statutory deadline is a mandatory procedural requirement under the state admission rules, and it does not constitute an arbitrary action when the institution fails to meet the prescribed cut-off date.

Headnote:(A) Chhattisgarh Medical, Dental and Physiotherapy Undergraduate Admission Rules, 2025 - R. 13

(B), 13(d) - Chhattisgarh Non-Resident Indian Quota in Private Professional Colleges Rules, 2017 - R. 4(6) - Conversion of NRI quota seats to management quota - Petitioner medical college challenged conversion of its unfilled NRI quota seats - Statutory timeline for NRI quota admissions fixed at 10 days before final admission cut-off date - Failure to fill seats within deadline triggers automatic conversion to management quota - Court upheld the conversion as lawful compliance with statutory mandate. (Paras 15, 16, 18, 19, 21, 22)

Facts of the case:
The petitioner, a medical institution, was granted conditional permission to participate in admission counseling. Following a notification, the administrative authorities converted the petitioner's unfilled NRI quota seats into management quota seats. The petitioner argued that this conversion was arbitrary, violated statutory rules regarding notice and hearings, and was contrary to directives from the High Court of Delhi allowing their late entry into the counseling process.

Findings of Court:
The Court held that the Rules of 2025 and 2017 prescribe a mandatory deadline for NRI quota admissions. As these seats were not filled by the statutory cut-off date, their conversion to management quota was an automatic consequence mandated by law, not an act of arbitrariness.

Issues: Whether the conversion of NRI quota seats to management quota by the State authorities was illegal or arbitrary under the governing Admission Rules despite the petitioner's recent entry into the counseling process.

Ratio Decidendi: Statutory deadlines for admissions in professional colleges are mandatory and non-negotiable. Where rules expressly provide for the conversion of unfilled quota seats into management category after a specific cut-off date, such conversion does not constitute a violation of principles of natural justice and is consistent with the regulatory objective of preventing vacant seats.

Result: Petition dismissed.

Table of Content
1. overview of institutional background and previous litigation regarding student admission permissions. (Para 1 , 2 , 3 , 4 , 5)
2. petitioner's contention regarding arbitrary conversion of nri seats to management category. (Para 6 , 7 , 8 , 9 , 10)
3. respondents' justification based on mandatory statutory timelines and admission rules. (Para 11 , 12 , 13)
4. interpretation of regulatory sections governing nri quota admission deadlines. (Para 14 , 15 , 16 , 17 , 18)
5. court's ruling that statutory timelines are binding despite late administrative permission. (Para 19 , 20 , 21 , 22 , 23)

Hon'ble Shri Ramesh Sinha, Chief Justice

Hon'ble Shri Bibhu Datta Guru, Judge

Order on Board

Per Ramesh Sinha, Chief Justice

14.11.2025

1. Heard Mr. Ashish Shrivastava, Senior Advocate assisted by Ms. Sangeeta Mishra, Mr. Ashutosh Shrivastava, Mr. Ishaan Singh Rathore and Ms. Shatabdi Bagchi, learned counsel for the petitioners. Also heard Mr. Sangharsh Pandey, learned Government Advocate, appearing for the State/respondents No.1 to 3, Ms. Anmol Sharma, learned Central Government Counsel appearing for respondent No.4 as well as Mr. Ranbir Singh Marhas assisted by Mr. Samarth Singh Marhas, learned counsel appearing for respondent No.5.

2. The present petition has been filed by the petitioner with the following relief(s):-

“10.1 It is prayed that this Hon'ble Court may kindly be pleased to call for the entire records pertaining to the case of the petitioner Company from the possession of respondents for its kind perusal.

10.2 That, this Hon'ble Court may kindly be pleased to issue an appropriate writ quashing and setting aside the impugned Notice dated 11.11.2025 (Annexure P/1) in respect of the petitioner.

10.3 That, this Hon'ble Court may kindly be pleased to issue an appropriate writ commanding the respondents to permit and allow the petitioner institution to participate in the counselling program for the admission in the NEET UG program 2025 for the remaining seats.

10.4 That, this Hon'ble Court may kindly be pleased to issue an appropriate writ commanding the respondents to conduct separate counselling of the petitioner institution as the petitioner institution was allowed to participate in the counselling program for the first time vide notice dated 09.10.2025 in view of the order dated 11.09.2025 passed by the Hon'ble High Court of Delhi.

10.5 Any other relief/reliefs, which this Hon'ble Court may think fit and proper in the facts and circumstances of the case, with cost of the petition, may also please be granted to the petitioner.”

3. Brief facts of the case, in a nutshell are that the petitioner Medical College and Research Centre was established at Naya Raipur (C.G.) in the academic year 2022–23 with the objective of imparting MBBS, BDS and other medical education programs to students within and outside the State, in full compliance with the norms prescribed by the erstwhile Medical Council of India and the National Medical Commission (NMC). The Institution was also granted a clinical establishment licence under Section 4 of the Chhattisgarh Clinical Establishments (Registration and Regulation) Adhiniyam, 2010 for running a hospital, pathology laboratory and allied medical facilities for a period of five years w.e.f. 22.08.2023 to 21.08.2028. The petitioner Institution was thereafter granted permission by the NMC for conducting various medical programs, including MBBS and BDS. Specifically, the NMC sanctioned an annual intake of 150 MBBS seats for the academic year 2024–25 under Sections 26(1)(A)(B) and 28(1)(2) of the NMC Act, 2019 vide permission letter dated 04.07.2024, upon due fulfillment of all statutory and infrastructural requirements for establishment of a new medical college under Pandit Dindayal Upadhyaya Memorial Health Sciences and Ayush University, Raipur.

4. Subsequently, an FIR was lodged by the CBI alleging involvement of the petitioner Institution in matters relating to seat enhancement. The said

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2025 Supreme(Online)(Chh) 19918

IN THE HIGH COURT OF CHHATTISGARH AT BILASPURRamesh Sinha, CJ, Bibhu Datta Guru, JShri Rawatpura Sarkar Institute Of Medical Science And Research Naya Raipur – AppellantVersusState Of Chhattisgarh – RespondentWPC No. 5989 of 2025

The conversion of unfilled NRI quota seats into management quota seats upon expiration of the statutory deadline is a mandatory procedural requirement under the state admission rules, and it does not constitute an arbitrary action when the institution fails to meet the prescribed cut-off date.

Cases Referred (1)

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ, Bibhu Datta Guru, J
Shri Rawatpura Sarkar Institute Of Medical Science And Research Naya Raipur – Appellant
Versus
State Of Chhattisgarh – Respondent
WPC No. 5989 of 2025