Medical College admissions - No Arbitrary reduction of intake capacity of MBBS seats
Kerala High Court Upholds Medical College's Right to Admit 150 MBBS Students. Court Rules Arbitrary Reduction of Seats Violates Article 14; Petitioner Allowed to Fill Seats Through Stray Vacancy Allotments
In a landmark judgment passed on October 8, 2025, the Kerala High Court, presided over by Justice N. Nagaresh, ruled in favor of V.N. Public Health and Educational Trust, allowing them to admit a second batch of 150 MBBS students for the academic session 2025-2026. The decision came after the trust challenged the Under Graduate Medical Education Board's order to reduce their intake capacity from 150 to 100 seats without giving adequate time to comply with updated regulations.
The trust, operating the Palakkad Institute of Medical Sciences, had been granted permission by the Apex Court to admit 150 students under the Minimum Requirements for Annual MBBS Admissions Regulations, 2020 (MSR-2020), despite the introduction of the Maintenance of Standards of Medical Education Regulations, 2023 (MSMER-2023). The court found the insistence on MSMER-2023 without reasonable notice arbitrary and in violation of Article 14 of the Indian Constitution, which guarantees equality before the law.
Justice Nagaresh emphasized that the respondents' decision to reduce the intake capacity was highly arbitrary, given that the petitioners were specifically directed by the Apex Court to comply with MSR-2020 standards for the academic year 2024-2025 due to peculiar circumstances. The court underscored that the petitioners were not given sufficient time or notice to transition to MSMER-2023, thereby breaching the principles of natural justice.
The judgment highlighted several deficiencies cited by the respondents in their show-cause notice, including faculty inadequacy and insufficient operational data, which the court found to be either resolved or trivial. The court noted that the petitioners had complied with the phase-wise requirements of MSR-2020, as the Apex Court had directed, and were entitled to enhance faculty strength gradually.
Furthermore, the court rejected the defense's argument regarding the availability of an alternate appellate remedy, stating that, given the timeline and facts of the case, such a remedy would not be efficacious.
With the Round-3 allotment process completed, the court directed the respondents to permit the petitioners to fill the remaining 150 MBBS seats through stray vacancy allotments. This decision underscores the judiciary's role in safeguarding educational institutions against arbitrary administrative actions that could hinder their operational capacities and student intake.
Bottom Line:
Medical College admissions - Arbitrary reduction of intake capacity of MBBS seats without providing reasonable time for compliance with updated regulations violates Article 14 of the Constitution of India.
Statutory provision(s): Article 14 of the Constitution of India, Minimum Requirements for Annual MBBS Admissions Regulations, 2020 (MSR-2020), Maintenance of Standards of Medical Education Regulations, 2023 (MSMER-2023).
