Studying Biology in Class 11 Not Mandatory for NEET-UG Eligibility if Passed in Class 12 as Additional Subject: Rajasthan High Court - 2025-11-20

Rajasthan High Court Upholds NEET Aspirant's Eligibility, Rules Biology in Class 11 Not Mandatory

JODHPUR: In a significant ruling providing relief to medical aspirants, the Rajasthan High Court has held that not studying Biology in Class 11 is not a ground to disqualify a candidate from NEET-UG admissions, provided they have passed the subject in Class 12, even as an additional subject.

The bench of Hon'ble Dr. Justice Nupur Bhati quashed the rejection of a meritorious student's candidature for an MBBS course and directed the authorities to grant him admission forthwith. The court found the rejection to be "unjust, arbitrary, and contrary to the decision of the National Medical Commission."

Background of the Case

The petitioner, Gopal Singh, a high-scoring student with a 99.43 percentile in the NEET-UG 2025 examination, challenged the rejection of his admission to a government medical college. After being provisionally allotted a seat at Government Medical College, Sri Ganganagar, his candidature was cancelled via an email dated October 1, 2025.

The sole reason cited for the rejection was that he had not studied Biology as a subject in Class 11. Singh had initially completed his senior secondary education with Physics, Chemistry, and Mathematics. Aspiring for a medical career, he later reappeared for the Class 12 examination, taking Biology as an additional subject, and passed with a first division.

Arguments Presented

Petitioner's Counsel, Mr. Sharad Kothari, argued that the rejection was illegal and arbitrary. He drew the court's attention to a Public Notice issued by the National Medical Commission (NMC) on November 22, 2023. This notice, in line with the new Graduate Medical Education Regulations, 2023, explicitly permits candidates who have passed Physics, Chemistry, and Biology/Biotechnology as additional subjects in Class 12 from a recognized board to appear for NEET-UG. He contended that the old rule requiring continuous study of Biology in both Classes 11 and 12 had been repealed.

Respondents' Counsel, Mr. Narendra Singh Rajpurohit (AAG), defended the decision, stating that the counseling checklist specifically required a Class 11 mark sheet showing Biology as a subject. He argued that the petitioner was aware of this requirement. The counsel also pointed to the NMC notice's phrasing, which allowed taking an additional subject "after passing Class 12th," suggesting it couldn't be done concurrently.

Court's Analysis and Reasoning

Justice Bhati meticulously examined the NMC's Public Notice and the Graduate Medical Education Regulations, 2023. The court observed that the regulatory landscape had fundamentally changed, moving away from the rigid requirements of the erstwhile Medical Council of India (MCI).

The judgment highlighted pivotal excerpts from the NMC's notice:

> "The National Medical Commission in its meeting held on 14.06.2023... decided that the previous approach of the erstwhile Medical Council of India needs to be revisited by permitting candidates to undertaken study of the requisite subjects (Physics, Chemistry, Biology / Biotechnology alongwith English) even as additional subjects after passing Class 12th from duly recognized boards..."

The court identified a crucial inconsistency in the regulations' wording. It noted that the phrase "after passing Class 12th" appeared to be a "drafting error" and should be interpreted as "at the time of passing Class 12th." The court reasoned that no practical mechanism exists for a student to take an additional Class 12 subject once the qualification has already been awarded. The AAG was unable to provide any clarification on this point.

The court concluded unequivocally:

> "From the above it is abundantly clear that there is no requirement whatsoever to have studied Biology in Class 11th. The only requirement is that the candidate must have passed the requisite subjects i.e. Physics, Chemistry Biology/Biotechnology and English from a recognized board..."

The court held that the petitioner, having passed Biology as an additional subject in his Class 12 examination, fully satisfied the eligibility criteria laid down by the NMC.

Final Verdict and Directions

Finding the rejection of Gopal Singh's candidature to be arbitrary, the High Court quashed and set aside the impugned email dated October 1, 2025.

Given that the petitioner had already been allotted a college in the third round of counseling pursuant to an interim court order, the bench issued a firm directive to the respondents to:

> "...accord the petitioner admission in the respective college forthwith and permit him to attend classes for the MBBS course."

This judgment clarifies the eligibility criteria under the new NMC regulations and ensures that a student's career prospects are not jeopardized by arbitrary interpretations of outdated or poorly drafted rules.