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2026 Supreme(Online)(Raj) 9568

HIGH COURT OF RAJASTHAN (JODHPUR BENCH)
Nupur Bhati, J
Parnika Sharma – Appellant
Versus
State of Rajasthan – Respondent
S.B. Civil Writ Petition No. 5344/2026



Advocates:
For the Appellants/Petitioners: Y.P. Khileree
For the Respondents: Bhutid Gehlot, Siddharth Tatia, Kanchan Jodha, N.S. Rajpurohit, T.C. Sharma

Statutory regulations governing medical admissions, which permit a one-month grace period for obtaining permanent registration after admission, override contrary administrative guidelines or information bulletins that demand such registration at the time of reporting.

Headnote:(A) Post-Graduate Medical Education Regulations, 2000 - Regulation 8(3) - Admission to post-graduate medical courses - Possession of Permanent Registration Certificate - Whether a mandatory pre-condition at the time of reporting - Regulation 8(3) allows a candidate to obtain permanent registration within one month from the date of admission - Administrative guidelines like NEET-PG Information Bulletin cannot override statutory regulations - Impugned action denying admission solely on non-production of permanent registration at the time of reporting is arbitrary and contrary to statutory mandate. (Paras 12, 13, 14, 16)

Facts of the case:
The petitioner, having completed her MBBS and internship, was allotted an M.D. (Anesthesiology) seat via NEET-PG 2025. She was denied admission by the college for failing to produce a Permanent Registration Certificate at the time of reporting, despite holding a Provisional Registration Certificate and having applied for the permanent one, which was subsequently issued during the pendency of the petition.

Findings of Court:
The court held that Regulation 8(3) of the Regulations of 2000 has clear statutory force and provides a one-month window for candidates to secure permanent registration post-admission, rendering the restrictive condition in the Information Bulletin legally untenable.

Issues: Whether the condition in the NEET-PG Information Bulletin requiring production of a Permanent Registration Certificate at the time of counseling/admission overrides the statutory provision in the Regulations of 2000 permitting a one-month grace period.

Ratio Decidendi: Statutory regulations occupy the field of admission criteria; where an administrative guideline—such as an Information Bulletin—is in conflict with a statute, the statutory regulation must prevail to prevent undue hardship and ensure meritorious candidates are not denied seats due to procedural timelines.

Result: Petition allowed.

Table of Content
1. petitioner challenges denial of medical admission due to absence of permanent registration. (Para 1 , 2)
2. counsel argues statutory regulations permit grace period for registration certificate. (Para 3 , 4 , 5 , 6 , 7 , 8)
3. statutory regulations prevail over administrative information bulletins regarding eligibility. (Para 9 , 10 , 11 , 12 , 13)
4. denial of admission is arbitrary and contrary to statutory grace period. (Para 14 , 15 , 16 , 17)

Order

1. The present writ petition has been filed with the following prayers:-

a) The impugned letter dated 28.02.2026 Annex. 16 issued by the respondent Dr. SN Medical College, Jodhpur may kindly be declared illegal & arbitrary and same may kindly be quashed and set aside;

b) The respondent no.5 may be directed to accept the reporting and joining of the petitioner in the M.D. (Anesthesiology) at respondent medical college pursuant to the allotment letter dated 23.02.2026 Annex.11 under the NEET PG-2025;

c) The respondents may be directed not to cancel the allotment of PG seat i.e. M.D. (Anesthesiology) pursuant to NEET PG 2025 at Dr. SN Medical College, Jodhpur due to not having Permanent Registration Certificate at present;

d) The respondent no.6, the Chhattisgarh Medical Council, Raipur as well as respondent no.7 may kindly be directed to issue Permanent Registration Certificate to the petitioner forthwith upon taking necessary bond/ undertaking from the petitioner as per law;

e) any other appropriate order, which is deemed just and proper in the facts and circumstances of the case may kindly be also passed; and

f) the petitioner may kindly be allowed the cost of writ petition.

2. Brief facts of the case, as stated in the writ petition, are that the petitioner completed her MBBS from Pt. Deendayal Upadhyay Memorial Health Sciences and Ayush University of Chhattisgarh on 13.03.2023 and thereafter obtained Provisional Registration from the Chhattisgarh Medical Council on 25.08.2023. She successfully completed her one-year compulsory rotating internship on 26.03.2024. Subsequently, she applied for Permanent Registration with the said Council and submitted her original provisional certificate. However, as per the Chhattisgarh UG Admission Rules, 2018, issuance of Permanent Registration is subject to completion of two years’ bonded State service or furnishing a bank guarantee/undertaking. In compliance thereof, the petitioner joined as a Medical Officer at Maharani Hospital, Jagdalpur, District Bastar (Chhattisgarh) on 24.08.2024 and has been serving there since then. Meanwhile, the petitioner appeared in NEET-PG 2025 conducted by the National Board of Examinations and secured 472 out of 800 marks with an All India Rank of 33498. She participated in the counselling process and was allotted an M.D. (Anesthesiology) seat at Dr. SN Medical College in the stray vacancy round, pursuant to which a provisional allotment letter dated 23.02.2026 was issued by the Medical Counselling Committee. The petitioner duly reported to the allotted college and submitted all requisite documents; however, she was denied admission solely on the ground that she did not possess the original Permanent Registration Certificate issued by the Chhattisgarh Medical Council and being aggrieved of the said action, the petitioner preferred the present writ petition.

3. Learned counsel for the petitioner submits that in compliance of the order dated 18.03.2026, additional documents have been placed on record i.e. the NEET-PG 2025 Information Bulletin and the Medical Council of India Postgraduate Medical Education Regulations, 2000 ('hereinafter referred as Regulation of 2000') as amended up to May 2018.

4. Learned counsel for the petitioner draws attention of the Court to Clause 4.1 of Chapter IV of the National Medical Council Notification dated 29th December, 2023, which prescribes the eligibility criteria for admission to postgraduate medical courses and provides that, until

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