High Court Rules Medical Colleges Must Comply with UG-MSR 2023 Requirements for Seat Renewals: Kerala High Court

In a significant ruling concerning the standards of medical education in India, the Kerala High Court has underscored the mandatory nature of the National Medical Commission’s (NMC) regulatory framework. The Division Bench, comprising Justice Anil K. Narendran and Justice Muralee Krishna S., overturned a Single Judge’s order that had previously allowed the Palakkad Institute of Medical Sciences to admit a full batch of 150 MBBS students despite failing to meet updated infrastructure and faculty requirements.

The Conflict of Regulations

The V.N. Public Health and Education Trust, which manages the Palakkad Institute of Medical Sciences, found itself at odds with the Under Graduate Medical Education Board (UGMEB). While the Trust argued that it should be permitted to admit 150 students based on older norms (MSR 2020) protected by a previous Supreme Court order, the NMC contended that the current academic cycle must strictly adhere to the Guidelines for Under Graduate Courses under the Establishment of New Medical Institutions, Starting of New Medical Courses, Increase of Seats for Existing Courses and Assessment and Rating Regulations, 2023 (UG-MSR 2023).

The dispute focused on whether the medical college, which had been granted a Letter of Permission (LoP) in 2024, could rely on the phase-wise compliance requirements of 2020 regulations or if it was required to immediately fulfill the more stringent standards set by the 2023 regulations.

Arguments from the Bench and Bar

The National Medical Commission, represented by the Additional Solicitor General, argued that judicial interference in such technical domains undermines the quality of medical education. They maintained that once the 2023 regulations came into force, all medical institutions—regardless of their year of establishment—were obligated to comply to ensure student training standards remain intact.

Conversely, the petitioners contended that they were not given adequate "breathing time" to meet the new criteria and that as a private trust, they had given an undertaking to comply within a year. They argued that the Single Judge’s initial decision to allow the full intake of 150 students was a reasonable exercise of equity.

Key Observations

The Division Bench was stern in its analysis regarding the limits of judicial discretion in the face of statutory mandates:

> "The Medical Council of India and the college authorities have to bear in mind that what is prescribed in the Regulations is the minimum. If the Medical Council of India dilutes the minimum standards, it will be doing violence to the statutory requirements."

The Court further clarified the distinction between temporary judicial relief and binding precedent:

> "The directions of the Court under Article 142 of the Constitution, while moulding the relief, that relax the application of law or exempt the case in hand from the rigour of the law, in view of the peculiar facts and circumstances, do not comprise the ratio decidendi and therefore lose its basic premise of making it a binding precedent."

Furthermore, in addressing the request for a writ of mandamus, the Court noted:

> "In such circumstances, this Court in exercise of the extraordinary jurisdiction of this Court under Article 226 of the Constitution of India cannot issue a writ of mandamus commanding the appellants and the 3rd respondent University to permit the medical institution in question to admit students in 150 MBBS seats in the second batch... since no mandamus can be issued directing the statutory authorities to do something contrary to the statute."

The Final Verdict: Statutory Compliance Is Non-Negotiable

The High Court set aside the Single Judge’s judgment, effectively supporting the NMC’s decision to limit the medical college to 100 MBBS seats for the 2025-26 academic session. The Court held that the petitioners had an efficacious alternative remedy-an appeal to the Central Government—which they chose to bypass by approaching the High Court directly.

This ruling reinforces the principle that health regulators must maintain autonomy over their standards. For medical institutions, the message is clear: academic requirements are absolute, and the judiciary will not step in to bypass regulatory compliance simply to facilitate an increase in institutional student intake.