Country lacks enough qualified doctors! SC allows medical degrees to students with invalid certificates, imposes Rs 10 lakh compensation each

New Delhi: In a partial relief to two medical students from Maharashtra who had secured admission using tribe certificates that were later found to be invalid, the Supreme Court of India has directed the Maharashtra University of Health Sciences (MUHS) to issue their medical degrees. 

The court observed that wasting their years of medical training would not be in the best interest of society, especially when the country already faces a shortage of qualified doctors.

Along with this direction, the apex court clarified that the students must deposit Rs 10 lakh each with the Vice-Chancellor of MUHS within three months before receiving their certificates. If they fail to deposit the amount within the stipulated time, the matter will be placed before the court again, and the direction to issue the degrees may be withdrawn.

Moreover, the court also recorded the students’ undertaking that they will not claim any future reservation benefits based on the cancelled tribe certificates.

Noting the shortage of qualified doctors in the country, a Division Bench comprising Justice Dipankar Datta and Justice Rajesh Bindal observed that granting degrees to the students who had completed their course and cleared examinations on merit, but whose tribe certificates were invalid, would not compromise merit. Instead, it would enable qualified doctors to serve the public.

The court said, 

"As it is, the country lacks enough qualified doctors. Granting partial relief to the appellants by directing the University to issue them the degrees/certificates thereby entitling them to join the medical profession, on facts and circumstances, would not compromise merit; rather, it would enable qualified doctors to serve the public. The service that these appellants could render to the society in the long run would outweigh the consequences stemming from the flaws in the admission process, which have subsequently come to the fore. A pragmatic view is what requires to be adopted."

The Bench further added, "A pragmatic view is what requires to be adopted. However, any undertaking given by the appellants not to claim reservation benefits in future would certainly not suffice. We are of the considered opinion that the appellants cannot be allowed to go scot-free so easily. It can hardly be ignored that in the process of admission based on certificates subsequently found invalid, the appellants had deprived eligible candidates who could have secured admission in their place on the basis of their genuine tribe claim; hence the appellants have to pay some price."

The top court was hearing an appeal filed by two students who had secured admission to medical courses on reserved seats based on tribe certificates. Later, their certificates were cancelled by the Scrutiny Committee. 

The High Court had earlier dismissed their writ petitions challenging the cancellation of their tribe certificates. Because of this, the university was unable to issue its degrees.

Appearing for the students, advocate Mr Karande argued that since they cleared the exams on merit and worked hard to complete the course, they should be allowed to receive their degrees. He also submitted that they are willing to give a written undertaking that they will not claim any reservation benefits in the future.

However, this argument was strongly opposed by Mr Deshpande, representing the University, and Ms. Bobde, representing the State. They contended that since the admissions were invalid from the beginning (void ab initio), the students should not be allowed to gain any benefit from such admissions.

After hearing both arguments, the court said there is no doubt that the appellants got admission based on tribe certificates that were later cancelled. However, the court said that it is important to note that their certificates were declared invalid only after they had completed their medical courses.

The judges observed, "Bearing in mind the fact that the appellants have completed their curriculum for the medical courses and ultimately succeeded in the examinations written by them, we are of the considered opinion that refusing even partial relief to them would not be in the best interests of society. After all, if indeed partial relief is refused, not only would the two seats occupied by the appellants go waste, their efforts in succeeding in the examinations would also be of little use for society. It is nobody’s case that the appellants succeeded in the examinations other than on merit."

The bench noted that allowing them to receive their degrees would not harm merit, as they cleared the exams fairly. Instead, it would enable trained doctors to serve society. 

Accordingly, the court passed the following directions:

1. The students must deposit ₹10 lakh each with the Vice-Chancellor of the Maharashtra University of Health Sciences within three months.
2. Once the amount is deposited, the University must issue their degrees within 24 hours.
3. After receiving the degrees, they can register with the appropriate medical council and start practising.
4. The University must identify the candidates who were deprived of admission because of the appellants occupying the reserved seats.

5. Upon such identification, the Vice-Chancellor of the University shall take steps for releasing the amounts in favour of the deprived candidates in terms of this order
6. If the students fail to deposit the money within three months, the matter will be placed again before the court, and the direction to issue degrees may be cancelled.

7. Once the sums of Rs.10,00,000/- are released in favour of the deprived candidates, the Vice-Chancellor may inform the same to the Secretary, Medical Education and Drugs Department, Government of Maharashtra.

8. The court recorded the undertaking of the students that they will not claim any future reservation benefits based on the cancelled tribe certificates.