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Upholds Four-Attempt Limit on First-Year MBBS Including Supplementary Exams
The has firmly rejected a first-year MBBS student's plea for an extra attempt to pass her professional examinations, ruling that the four-attempt cap prescribed by the unambiguously covers both regular and supplementary examinations. The dismissal underscores the judiciary's reluctance to interfere with academic regulations, especially those governing medical education.
The Case: A Student's Struggle with MBBS Exams
Krishnapriya M, a 22-year-old student at , joined the MBBS program in . She failed three core subjects—Human Anatomy, Physiology, and Biochemistry. Over four years, she took four examination attempts but could not clear all subjects. At the end of this period, she approached the High Court seeking permission to appear for a "" or an additional attempt within the four-year timeline. Her college, the , and the all opposed the request, pointing to the strict limit in .
The Regulation: GMER 's Four-Attempt Cap
states:
"Under no circumstances students shall be allowed more than four (04) attempts for the first year (First Professional MBBS) and no student shall be allowed to continue undergraduate medical course after nine (09) years from the date of admission."
The NMC guidelines further clarified that a candidate who fails the supplementary exam in Phase I joins the junior batch and that
"no more than four attempts shall be allowed for a candidate to pass the Phase I Examination."
Court's Ruling: Plain Meaning Prevails
Justice Bechu Kurian Thomas, writing the judgment, rejected the petitioner's argument that the four attempts should only count regular examinations. The court applied the
, holding that
"the words 'four attempts for first year Professional MBBS' clearly indicates that irrespective of whether it is regular examination or supplementary examination, a student has only four attempts."
The court noted that for a failed candidate, the first attempt is the only "regular" one; every subsequent attempt is inherently supplementary. Therefore, the regulation's use of the term "attempts" includes all.
The court specifically stated:
"This Court is of the view that a candidate can avail only four attempts, irrespective of whether it is regular or supplementary and once such attempts are availed, a further opportunity cannot be granted."
Precedent: 's Approach
The judgment drew support from the 's decision in
Sachin and Others v. Union of India and Others
(WP(C) No.13180/
). In that case, the
observed that
"medicine is a noble profession"
and that regulations capping attempts are not arbitrary. The court further noted that a candidate has no
to take an examination an unlimited number of times.
Key Observations
The emphasized that academic prescriptions should not be tampered with lightly:
"
with Regulations framed by academic bodies ought not to be done casually. Even if a specific Regulation leads a student to difficulty, the same is not a reason for this Court under
to interfere. This is all the more so when the issue under consideration relates to students of medicine, who ultimately cater to the needs of health of the society, whose competence has a direct bearing on public health and safety."
Court's Decision: Petition Dismissed
Finding no exceptional circumstances, the court dismissed the . The decision reinforces the strict enforcement of GMER provisions, making it clear that medical students must pass their first-year examinations within four attempts—whether regular or supplementary—or face the end of their undergraduate journey. The ruling serves as a reminder that academic rigor in medical education is a matter of , not judicial sympathy.
