Court rules fragmented residency tenure across multiple institutions meets eligibility criteria, ensuring fairness and meritocracy in admissions.
In a landmark judgment, the Delhi High Court has overturned the decision of the All India Institute of Medical Sciences (AIIMS), New Delhi, to reject the candidature of Meet Bhadresh Shah for admission into the DM Critical Care Medicine programme. The Court ruled that fragmented residency tenure across different institutions, fulfilling the cumulative requirement of 1095 days, cannot be grounds for rejection when the prospectus does not explicitly mandate continuity from a single institution.
Justice Jasmeet Singh presided over the case, wherein the petitioner, Meet Bhadresh Shah, challenged AIIMS's rejection letter dated January 2, 2026. Shah had completed his postgraduate residency tenure in Anaesthesiology through authorized transitions between three institutions due to COVID-19-related delays in counseling procedures. Despite securing an All India Rank of 4 in the Institute of National Importance Super-Speciality (INI-SS) Entrance exam, AIIMS had canceled his admission citing non-continuous residency tenure from a single institution.
The Court emphasized that the prospectus issued by AIIMS was silent on the continuity requirement from a single institution, and therefore, the rejection of Shah's candidature was deemed arbitrary and violative of Articles 14 and 16 of the Constitution, which ensure equality and fairness in educational opportunities. The judgment underscored the importance of merit and fairness over technicalities in higher education admissions.
Justice Singh highlighted the need for restraint in judicial interference in academic matters but asserted that courts must intervene in cases of arbitrariness. The Court noted that Shah's completion of 1095 days of residency across different institutions adhered to the prospectus's requirements, as no express exclusion was specified.
The ruling is expected to have significant implications for medical education, reinforcing the principle that eligibility criteria must be clear, explicit, and uniformly applicable, ensuring that deserving candidates are not denied educational opportunities due to procedural ambiguities.
Bottom Line:
Higher education - Fragmented residency tenure from different institutions fulfilling the cumulative requirement of 1095 days cannot be a ground for rejection when the prospectus does not explicitly mandate continuity from a single institution.
Statutory provision(s): Constitution of India, Articles 14, 16, PGME regulations, 2023, Clause 4.3.2 of the AIIMS prospectus.
Meet Bhadresh Shah v. All India Institute of Medical Sciences, (Delhi) : Law Finder Doc id # 2847363
