NCC Certificate 'A' Holders Excluded From NEET Grace Marks Reasonable Classification : Telangana High Court

The Telangana High Court has upheld the State’s policy of awarding grace marks in NEET admissions only to NCC cadets holding Certificate ‘B’, while excluding those with Certificate ‘A’. A Division Bench of Justice P. Sam Koshy and Justice Narsing Rao Nandikonda ruled that the classification is reasonable and does not violate Article 14 of the Constitution .

The decision came in a writ petition filed by Chatla Susheel Kumar, a minor represented by his father, challenging Clause (iii)(a) of Rule 4 of the Telangana Medical and Dental Colleges Admission Rules, 2017 , as amended by G.O.Ms.No.75 dated July 4, 2023 . The provision grants NCC cadets who have obtained a ‘B’ Certificate before the qualifying examination a 3% addition to their NEET score, but offers no such benefit to ‘A’ Certificate holders.

Background: From Reservation to Grace Marks

Until the 2024-25 academic session , the State reserved 1% of MBBS and BDS seats horizontally for NCC cadets under a graded scheme. In 2023 , the government replaced that reservation with a system of grace marks , intending to benefit a broader base of NCC cadets who qualify NEET. The revised policy grants marks based on participation in Republic Day Camp (7%), Thal Sainik or Vayu Sainik Camp (5%), and possession of NCC ‘B’ Certificate (3%). Holders of the ‘A’ Certificate were left out entirely.

Petitioner’s Arguments: Arbitrary Discrimination

Senior Advocate B. Mayur Reddy , representing the petitioner, argued that the training undertaken for Certificate ‘A’ and ‘B’ is substantially similar, differing only in the educational stage at which the cadet receives the certificate. Certificate ‘A’ is awarded to students up to Class X, while Certificate ‘B’ is given to those beyond Class X. The petitioner contended that excluding ‘A’ holders solely on this basis is arbitrary and violates the right to equality under Article 14, especially when the State’s stated goal is to incentivize NCC participation.

Respondent’s Defense: Policy Prerogative and Precedent

The Government Pleader for Medical and Health submitted that the writ petition was not sustainable in light of an earlier Division Bench decision in Silamkoti Yanjleena vs. State of Telangana ( 2025 ), which had already upheld the shift from reservation to grace marks as a legitimate policy choice . The State argued that the classification was based on intelligible differentia —the ‘B’ Certificate reflects continued NCC participation through Class XII, the stage at which a candidate becomes eligible for NEET.

Court’s Analysis: Reasonable Classification

The Bench distinguished the present challenge from the earlier one, noting that the previous decision dealt with the overall shift in policy, while this petition specifically targeted the exclusion of ‘A’ Certificate holders. On the merits, the Court applied the two-pronged test from the Supreme Court ’s ruling in Deepak Sibal vs. Punjab University ( 1989 ): the classification must be founded on an intelligible differentia , and that differentia must have a rational nexus to the object sought to be achieved.

The Court observed that Certificate ‘A’ is obtained by students below Class X, whereas Certificate ‘B’ requires completion of Class XII—the minimum qualification for NEET. The government’s objective was to reward cadets who remained in NCC until the point of NEET eligibility, thereby encouraging sustained participation.

“This, in the opinion of this Bench, is in itself a reasonable classification which can be drawn by the policy-makers,” the judgment stated.

Key Observations

The Bench emphasized that judicial review of policy decisions is limited. It quoted the earlier Division Bench: “The Court does not sit in appeal to examine the wisdom or efficacy of a policy formulated by the State. The choice between providing a reservation quota or awarding grace marks is a matter of legislative and executive policy, in which the interference of this Court is very limited and restrictive.”

On the specific classification, the Court noted: “Insofar as exclusion of Certificate ‘A’ holders from being awarded grace marks , what is prima facie appearing is that Certificate ‘A’ is provided to students below Class X, and Certificate ‘B’ is awarded to students who have done Class X + 2. Therefore, Class X + 2 is the minimum qualification required for participating in the NEET examination and therefore the Government decided to provide grace marks for students having Certificate ‘B’.”

Decision

The Court found no constitutional or legal infirmity in the classification and dismissed the writ petition with no order as to costs . The judgment clarifies that states may adopt differentiated incentives for NCC cadets as long as the classification bears a rational connection to a legitimate goal—here, encouraging continued NCC participation through the NEET-eligible stage.