Denied AIIMS MD Pharmacology admission as documents were with another medical college, Doctor gets Delhi HC relief

New Delhi: Observing that a meritorious student should not suffer due to systemic and administrative deficiencies operating within the admission framework, the Delhi High Court recently directed the All India Institute of Medical Sciences (AIIMS) Bhubaneswar to admit a candidate who secured seats in both NEET PG and the Institute of National Importance Combined Entrance Test counselling.

The candidate was denied admission because his original documents remained in the custody of another medical college. However, the HC bench comprising Justice Jasmeet Singh observed, "A meritorious candidate cannot be made to suffer owing to systemic and administrative deficiencies operating within the admission framework. The rigidity of procedural requirements cannot be permitted to defeat substantive justice, particularly where the eligibility and bona fides of the candidate are otherwise undisputed."

"Rule and regulation are handmaid of justice and cannot come in the way of Court granting substantive relief who is not only meritorious and has secured admission in a fair transparent and competitive manner," it further noted.

Background: 

These observations were made by the Court in its May 29 order while considering a plea filed by a student seeking admission to the MD (Pharmacology) course at the All-India Institute of Medical Sciences (AIIMS) in Bhubaneswar.

After clearing the MBBS exam, the petitioner participated in NEET PG 2025 and INI-CET January 2026 examination for PG medical admission. The petitioner secured a rank in the NEET PG 2025 and INI-CET January 2026 session and was allotted a seat in the third round of Counselling of NEET PG 2025 in RDMC, Banda in MD (Physiology) Course on 06.03.2026. While the result for INI-CET Open Round was awaited, the petitioner provisionally took admission in RDMC on 07.02.2026 and completed the admission formalities by depositing his original documents and certificates.

Consequently, the result for INI-CET Open Round Counselling conducted by AIIMS New Delhi was declared on 21.02.2026 where the petitioner secured a seat in MD (Pharmacology) course in AIIMS Bhubaneswar. However, his admission was denied as he failed to submit the original documents

The petitioner submitted his resignation vide email dated 21.02.2026 to RDMC to facilitate his move to AIIMS, Bhubaneswar and also physically visited RDMC, wherein he was informed that no provision for “resignation” existed and therefore his resignation could not be accepted.

Consequently, the petitioner physically reported to AIIMS, Bhubaneswar on 26.02.2026 i.e. before the deadline 28.02.2026 seeking provisional admission on the basis of an undertaking. However, since the original academic documents were not returned to the petitioner by RDMC, AIIMS Bhubaneswar refused admission in the absence of original documents. Following this, the petitioner filed a plea before the Delhi High Court. The Court on 12.03.2026 granted interim protection to the petitioner regarding his seat at AIIMS Bhubaneswar.

The counsel for the petitioner argued that equitable jurisdiction under Article 226 of the Constitution of India is not merely limited to correcting mistakes of the state, it also extends to preventing injustices caused by systemic failures beyond petitioner's control. The Court under Article 226 of the COI must intervene where the application of rules in the specific circumstances results in an arbitrary and unjust outcome.

Further relying on the judgment in the case of Asha v. Pt. B.D. Sharma University of Health Sciences (2012) 7 SCC 389, the counsel argued that a meritorious student cannot be denied admission due to circumstances beyond his control and no fault of his own. The acts of the petitioner such as resigning on the day of declaration of results, travelling to Bhubaneswar sending scanned documents and offering an undertaking demonstrates clear bonafides on part of the petitioner, he argued.

He also submitted that the forfeiture of Rs. 3 lakhs, which was furnished as a security deposit, is arbitrary and unconscionable as the same is taken to deter the candidate from casually abandoning the confirmed seat. The petitioner never abandoned the seat, he immediately wrote representations and resigned.

On the other hand, the counsel for AIIMS submitted that AIIMS Bhubaneswar acted in terms of the prospectus. Part A of the prospectus clearly notes that physical verification with reference to the original documents will be done at the time of reporting and candidature shall be subject to verification. Further Part B of the prospectus reiterates the same. Furthermore the result notification dated 21.02.2026 mentioned that the candidature shall be cancelled if the candidate fails to submit the required documents/certificates. Therefore, the institute acted within the four corners of the prospectus.

Observations by High Court: 

After considering the arguments, the HC bench perused various sections of the prospectus of INI-CET Examination and observed, "A perusal of the above sections of the prospectus sheds light upon the role of AIIMS, New Delhi. It was not only entrusted with the task of conducting the examination of INI-CET, wherein the petitioner secured a seat, but was also given the authority to initiate any legal or disciplinary actions in case the documents submitted by the candidates were forged or fabricated. Further the prospectus makes it crystal clear that AIIMS, New Delhi is the sole authority responsible for Seat Allocation among other things. To my mind, the issue in the present case pertains to seat allocation, and therefore the Cause of Action squarely falls within the territorial jurisdiction of this Court as the agency responsible for such seat allocation, i.e. AIIMS, New Delhi, is situated in Delhi."

One of the primary reliefs prayed for, among others, is to keep the allotted seat to the petitioner in AIIMS Bhubaneswar vacant and grant the petitioner provisional admission on the seat allotted and the release of 3 lakhs security deposit paid by the petitioner, noted the Court.

From the facts, the court noted that immediately after securing admission with AIIMS Bhubaneswar, the petitioner approached RDMC. Referring to this, the bench noted, "This reflects the bonafide on behalf of the petitioner to secure his original documents. However, despite his efforts the documents remained in the custody of the respondent No. 5 which made it impossible for the petitioner to produce the originals before the respondent No. 2 within the timeline stipulated. This inability cannot be construed as a negligence or the lack of intent on part of the petitioner rather it is a systemic failure on part of authorities concerned."

The bench noted that the petitioner is a meritorious student who has, through substantial academic effort, hard work and merit based competition, secured a seat in AIIMS Bhubaneswar.

"Admittedly, once the petitioner has secured admission, there existed no mechanism which enabled the petitioner to formally resign from the seat allotted at respondent No. 5. The same is also evident from the letter dated 23.02.2026 reproduced above. The petitioner has secured the allotment of seat in respondent No. 2 on merit and cannot be denied admission for non-supply of documents which are under the respondent No. 5‟s (RDMC) possession. Therefore, denial of admission to the petitioner solely on account of non-production of documents which remained withheld by respondent No. 5 would amount to penalising the petitioner for no fault attributable to him," the Court observed.

The bench denied to accept the argument that the admission was denied in strict compliance with the prospectus. A meritorious candidate cannot be made to suffer owing to systemic and administrative deficiencies operating within the admission framework, it noted.

"It is also to be noted that the petitioner does not seek exemption from verification, rather, the petitioner‟s case arises out of failure on part of the respondent No. 5 to release the original documents in its custody which made it physically impossible for the petitioner to produce them for verification. Thus, the petitioner cannot be faulted for the circumstances arising out of administrative vacuum and procedural inflexibility on part of respondent No. 5 and other authorities concerned," it further observed.

"Reliance placed on Varun Kumar Agarwal  also does not help the case of the respondents. Relying on the said judgment the respondents argue that respondent No. 2 has correctly the rejected the candidature of the petitioner as the submission of original documents was condition precedent and was so clearly mentioned in the prospectus. The judgment of Varun Kumar Agarwal  was predicated on the fact that AIIMS had expanded the zone of consideration of students by changing the contents of prospectus midway after the publication of the results. In the present case, even though the prospectus lays down the requirement that physical verification of the documents is necessary, the inability to do so on part of the petitioner was due to the failure of the respondent No. 5 to release the documents and the systemic failure which did not give option to the petitioner to resign. The broader purpose of such physical verification was to verify the identity of the petitioner. The same was fulfilled by the coloured scans of the documents and the undertaking that the documents were in possession of RDMC which was further fortified by the independent letter of RDMC to DHGS. The prospectus cannot be read rigidly so as to debar a meritorious candidate especially when the larger purpose of the condition prescribed has been fulfilled," held the bench.

Accordingly, the bench granted relief to the petitioner and ordered, "In view of the above discussion, the petition is allowed and the respondent No. 5 is directed to release the documents in its possession within 1 week from the uploading of this order. The respondent No. 1 and 2 are further directed to accept the documents from the petitioner and if found in order, grant admission to the petitioner in MD (Pharmacology) course in the respondent No. 2."

To view the order, click on the link below:

https://medicaldialogues.in/pdf_upload/2026/06/06/aiims-bhubaneswar-352272.pdf

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