Tracking Legal Developments.

Manipur High Court Intervenes in JNIMS PG Medical Seat Dispute, Moulds Relief to Accommodate Doctors

Imphal, Manipur - In a significant ruling addressing a complex dispute over a Post-Graduate (PG) medical seat in Radiodiagnosis at the Jawaharlal Nehru Institute of Medical Sciences (JNIMS), the High Court of Manipur, helmed by Hon'ble Mr. Justice A. Guneshwar Sharma , has exercised its extraordinary powers under Article 226 of the Constitution to "mould relief" and do complete justice to the involved parties. The Court directed the adjustment of one doctor to a subsequently vacated PG seat in Medicine, thereby paving the way for another to be considered for the contentious Radiodiagnosis seat, while upholding the principle of institutional reservation.

The judgment, dated June 11, 2025, arose from two writ petitions: WP(C) No. 218 of 2025 filed by Dr. Ibetombi Kshetrimayum , and WP(C) No. 295 of 2025 filed by Dr. Mutum Anilkumar Singh .

Case Overview

The core of the dispute revolved around the admission to a PG seat in Radiodiagnosis under the JNIMS sponsored category for the academic session 2024-2025. Dr. Ibetombi Kshetrimayum , a Senior Resident in Radiodiagnosis at JNIMS, challenged the admission of Dr. Mutum Anilkumar Singh , a Senior Casualty Medical Officer at JNIMS, to this seat.

Dr. Anilkumar Singh was admitted during the 3rd round of PG counselling when the NEET-PG cut-off was 15th percentile. Dr. Ibetombi Kshetrimayum , who initially did not qualify, became eligible when the NEET-PG cut-off was subsequently lowered to the 5th percentile. She contended that under JNIMS's own rules (specifically, notifications dated 16.02.2022 and 21.10.2022), Dr. Anilkumar Singh was obligated to surrender the seat in her favour, as she belonged to the prioritized category of Senior Residents.

Dr. Anilkumar Singh , in turn, filed a separate writ petition challenging the validity of Para (iii) of the notification dated 21.10.2022, which mandated such surrender, terming it discriminatory.

Key Arguments

Dr. Ibetombi Kshetrimayum (Petitioner in WP(C) No. 218 of 2025): * Argued that JNIMS rules (Notification dated 16.02.2022 reserving 14% state open quota seats for 'teachers' like Senior Residents, and Notification dated 21.10.2022 extending this to Casualty Medical Officers with a surrender clause) were binding. * Contended that Dr. Anilkumar Singh , having been admitted under the scheme, must surrender the seat as per Para (iii) of the 21.10.2022 notification once a Senior Resident (like herself) became eligible. * Asserted that the Supreme Court's judgment in Dr. Tanvi Behl v. Shrey Goel & Ors. (2025 INSC 125), which barred residence-based reservation, did not invalidate JNIMS's institutional reservation for its employees. * Highlighted that the Radiodiagnosis seat under this quota was available only once in 2024 over a five-year roster, making this her only chance.

Dr. Mutum Anilkumar Singh (Respondent No. 4 in WP(C) No. 218 of 2025 & Petitioner in WP(C) No. 295 of 2025): * Argued his admission was valid, based on merit in the 3rd round of counselling. * Challenged Para (iii) of the 21.10.2022 notification (the surrender clause) as arbitrary, discriminatory, and creating class legislation among JNIMS employees with MBBS degrees. * Claimed immense hardship if his admission was cancelled, including forfeiture of fees, bond, and ineligibility for future NEET-PG exams. * Invoked principles of legitimate expectation and estoppel against JNIMS.

State of Manipur & JNIMS (Respondents): * Initially contended that the JNIMS notifications regarding sponsored candidate reservations were superseded by the Supreme Court's judgment in Dr. Tanvi Behl . * However, the Learned Advocate General later conceded that Dr. Tanvi Behl barred residence-based reservation, not institutional reservation, and that the JNIMS rules provided for institutional reservation.

Court's Analysis and Reasoning

Justice A. Guneshwar Sharma meticulously examined the JNIMS notifications, the Supreme Court's precedent in Dr. Tanvi Behl , and various legal principles.

Institutional Reservation vs. Residence-Based Reservation: The Court found that the JNIMS notifications (16.02.2022 and 21.10.2022) provided for institution-based reservation for JNIMS employees, which is permissible as per Dr. Tanvi Behl . > "[70] ...This Court is of the considered view that these two notifications cannot be termed as resident-based reservation, rather they are institution-based reservation. Hence, the decision in Dr. Tanvi Behl case (supra) of non-permissibility of admission in PG course in Medicine on the basis of residence, will not be attracted to the schemes as alleged by the JNIMS."

Doctrine of Approbate and Reprobate: The Court noted that Dr. Anilkumar Singh had taken admission under Para (i) of the 21.10.2022 notification and thus could not, in the same breath for the purpose of retaining that specific seat, challenge Para (iii) (the surrender clause) of the same notification. > "[77] ...In the peculiar facts of the case, once he has taken admission in PG course against the seat reserved for Senior Resident/Tutor/Demonstrator/Lady Medical Officer under Para (i) of the notification dated 21.10.2022, it may not be proper for him to challenge Para (iii) of the same notification on the ground that the condition for surrendering the seat by Senior Casualty Medical Officer/Casualty Medical Officer is arbitrary, discriminatory, harsh and without any basis. The same will be barred by the principle of approbate and reprobate."

Moulding of Relief for Complete Justice: Acknowledging the "conflicting rights of two persons claiming under the same rules" and the potential hardship to both, the Court decided to mould the relief. > "[80] If the writ petition is allowed, it will cause immense hardship, inconvenience and loss of academic year to the respondent No. 4. If the writ petition is dismissed, it will also cause injustice to the petitioner as she has a right to be considered for admission... While deciding this case, the Court has to find a mid-way where both parties can have something."

The Court took note of a subsequently available vacant PG seat in General Medicine at JNIMS due to the resignation of another doctor. It also considered a previous instance where a similar adjustment was made by the Court. > "[86] ...this Court is of the considered view that it will suffice, just and proper if respondent No. 4 is adjusted against the PG seat in Medicine vacated by one Dr. Md. Mosmir... and in the seat of PG in Radiodiagnosis to be vacated by the respondent No. 4, the petitioner and similarly situated candidates... are to be considered."

Final Decision and Implications

The High Court disposed of WP(C) No. 218 of 2025 with the following directions: 1. Dr. Mutum Anilkumar Singh 's admission is to be adjusted against the vacant PG seat in General Medicine in JNIMS. Fees paid and bond submitted for Radiodiagnosis will be adjusted. 2. Dr. Ibetombi Kshetrimayum (and any other eligible candidates from the 'teacher' category in Radiodiagnosis at JNIMS) to be considered for admission to the PG seat in Radiodiagnosis to be vacated by Dr. Anilkumar Singh , as per Para (iii) of the 21.10.2022 notification. 3. This adjustment was termed a "one-off exercise" undertaken in the extraordinary power under Article 226 and not to be treated as a precedent, considering the unique facts, including the single opportunity for the petitioner in Radiodiagnosis under the scheme.

The Court clarified that it expressed no opinion on the general legality of Para (iii) of the 21.10.2022 notification, which remains to be considered in WP(C) No. 295 of 2025, listed for July 9, 2025. JNIMS was also given liberty to reconsider the problematic "surrender clause."

This judgment underscores the judiciary's role in balancing competing legitimate claims and its power to mould relief to achieve equitable outcomes, particularly in complex service and admission matters governed by intricate institutional rules.