State Cannot Re-Impose Cut-Offs After INC Relaxation: Chhattisgarh High Court

In a significant ruling, the High Court of Chhattisgarh has reinforced the supremacy of central regulatory bodies in determining educational standards. Justice Amitendra Kishore Prasad, presiding over a batch of writ petitions, ruled that the State Government lacks the authority to independently prescribe minimum qualifying benchmarks after the Indian Nursing Council (INC) has explicitly relaxed such criteria to facilitate the admission of students into B.Sc. (Nursing) courses.

The Conflict of Authority The dispute arose from the admission process for the 2025-2026 academic session. Following standard entrance examinations, a massive number of seats—roughly 4,147 out of 7,811—remained vacant, as many candidates failed to meet the stringent percentile requirements. Recognizing this, the State Government sought relaxation from the INC. While the INC acceded by permitting a fresh round of counselling with relaxed standards, the State’s medical education authorities unilaterally imposed a 10th percentile floor for participation.

The Private Nursing College Association of Chhattisgarh and a group of student petitioners challenged this move, arguing that the State was attempting to "legislate" its own standards where the field was already occupied by the statutory framework of the Indian Nursing Council Act, 1947 .

Arguments on Legal Competence The petitioners contended that once the INC—as the apex statutory body—relaxed the percentile requirements, the State was obligated to act as a pure implementing agency. By introducing an arbitrary 10th percentile, the State, they argued, was "rewriting the rules" and frustrating the purpose of the relaxation. Moreover, the students highlighted that this uniform 10th percentile ignored the statutory protections and category-wise relaxations guaranteed to reserved groups (SC/ST/OBC) under existing welfare norms.

The State, however, maintained that the INC’s "no objection" did not imply a total abolition of merit-based standards, arguing that their decision to set a 10th percentile was a reasonable administrative exercise to preserve academic quality.

Key Observations The Court's legal analysis centered on the harmony between the Central Act and the Chhattisgarh Nursing Admission Rules, 2019 . Justice Prasad emphasized that the State Rules explicitly subordinate local criteria to the INC’s mandates.

"...whenever the Indian Nursing Council prescribes, modifies or relaxes the qualifying standards, the respondent-State is under a statutory obligation to faithfully implement such directions. It cannot selectively adopt one part of the direction and simultaneously substitute another part by introducing a condition of its own."

The Court further observed:

"Once the expert statutory body constituted under the Central enactment exercised its statutory discretion and relaxed the qualifying percentile, the State Government had no authority either to curtail the extent of such relaxation or to substitute the same by prescribing an altogether new qualifying standard."

The Verdict and Its Impact Relying on precedents such as Maa Vaishno Devi Mahila Mahavidyalaya v. State of Uttar Pradesh and the principles in Asha v. Pt. B.D. Sharma University , the High Court quashed the State’s mandate of a 10th percentile benchmark.

The Court directed the respondents to conduct a fresh round of counselling specifically for the vacant seats, ensuring that admissions are based on inter-se merit without the unauthorized rider of a 10th percentile cut-off. To address the potential of an exhausted academic calendar, the Court ordered that institutions hold mandatory extra classes for the newly admitted students to bridge the gap in curriculum delivery.

This judgment serves as a stern reminder that administrative efficiency does not grant State authorities the power to override central regulatory expert bodies, especially when the latter has clearly defined the landscape for educational eligibility.