CPS doctors raise concerns over recognition as NMC proposes draft amendment to registration regulations
New Delhi: The National Medical Commission's (NMC) latest draft amendments to the Registration of Medical Practitioners and Licence to Practice Medicine Regulations, 2023 have raised concerns among CPS doctors over the recognition of their postgraduate qualifications.
The issue affects more than 40,000 doctors who have completed College of Physicians and Surgeons (CPS) programmes, while around 2,300 students are still awaiting their final CPS examinations.
The concern follows the draft’s proposed definition of “Additional Qualifications”, which links such qualifications to those recognised under the NMC Act, 2019 and obtained in accordance with postgraduate medical education regulations. The doctors are concerned that the new framework may leave already-qualified CPS specialists unable to obtain registration of their additional qualifications as it refers to NMC-recognised qualifications.
Meanwhile, the Government is still considering pan-India recognition of CPS graduates, and a related plea is also pending before the Supreme Court, which is likely to hear the matter on 20.08.2026. The CPS doctors have pointed out that with the judicial proceedings concerning the future of CPS students and qualifications still pending, a new registration framework dealing specifically with additional qualifications is being proposed.
Commenting on the matter, Dr. Jignesh Thakkar, the President of the CPS Doctors Association and a Senior Radiologist working in Thane, told Medical Dialogues, "Just because of the mistake, oversight, and ignorance of the government- MCI, now NMC, and the Ministry and State Government and the DMER- why are students held ransom?"
Highlighting that the Government was aware all the while regarding the admissions, he further added, "Instead of finding out the solution, they cannot penalise the students. Had they told our students that this was going to happen or that this is illegal, or state-wise, don't take admissions, then people would not have taken admission."
"Why is there a stepmotherly attitude of the Government?" he asked.
Demands for the pan-India recognition of CPS graduates have been a long-pending issue. Earlier this year, a large group of CPS doctors and students gathered outside the NMC office in Dwarka protesting against the huge delay in conducting the CPS examinations and the decision of not allowing CPS graduates to practice pan-India.
NMC draft amendment
On 11.08.2026, through a gazette notification, the Ethics and Medical Registration Board (EMRB) of the National Medical Commission (NMC) has issued draft amendments to the Registration of Medical Practitioners and Licence to Practice Medicine Regulations, 2023. Withdrawing the earlier draft released on 7th April 2026, the Commission has released a fresh draft which proposes to amend clauses 2, 3, 4, 5, 6, 7, 8, 10, 11, 12, 13, and insert 9A and delete clause 9.
NMC has proposed to substitute Regulation 2, Clause (a) as "“Additional Qualifications” are those qualifications other than the Primary Medical Qualifications duly recognized under Chapter VI of the NMC Act 2019 and obtained by Registered Medical Practitioner as per Post Graduate Medical Education Regulations."
CPS doctors concerned
The proposed framework has raised concerns among thousands of doctors who have already completed CPS qualifications and are practising as specialists in different States. They fear that the NMC could finalise the new national registration framework before the status of existing CPS qualifications is resolved, potentially affecting doctors who are already qualified and practising.
According to them, the NMC and the Union Health Ministry, which has already sought detailed course-wise information regarding CPS qualifications, should first resolve the issue of already-qualified CPS doctors before finalising a framework which may directly affect their additional-qualification registration.
"They have given 30 days' notice to all to submit their dissatisfaction with the notice; therefore, we are really relying on the media to let them know about our concerns and dissatisfaction. All we want is that, until and unless a clear-cut demarcation regarding our recognition is mentioned, NMC should abstain from publishing any gazette regarding medical practice that debars all who are not covered under the NMC Act, 2019," said Dr Abhijeet Kumar, Treasurer of CPS Doctors' Association.
Apart from the pan-India recognition issue, the CPS doctors have also highlighted the issues faced by 2,300 CPS postgraduate students, whose final specialist examinations have remained pending for a prolonged period.
Medical Dialogues had earlier reported that more than 2,300 postgraduate CPS doctors are facing uncertainty as their final examinations for specialist qualification have not been conducted for more than a year. On March 5, 2026, a large group of affected doctors staged a peaceful protest at Azad Maidan, demanding that the state government and the medical education department conduct their long-delayed postgraduate examinations.
The issue commenced after the recognition for CPS diplomas and postgraduate programmes was withdrawn in 2022. However, students who had taken admission in the 2021–22 academic session through NEET-PG were allowed to continue their courses. Authorities had assured them that they would be able to complete the programme. Many of these students have now completed their two-year training programmes. However, their final examinations have not been conducted since November 2024, leaving them without certificates and unable to practise as specialists.
Explaining the issue in detail, Dr. Nishit Trivedi, the Vice President of CPS Doctors Association, told Medical Dialogues, "The problem started when NMC came into existence. Earlier, before NMC, the State used to have the power to start, recognize or derecognize any course. On that basis, CPS courses were recognized by various States, such as Maharashtra, Gujarat, Dadra and Nagar Haveli, Daman and Diu, Punjab, Odisha, and West Bengal. Now, NMC is coming out with these regulations that only postgraduate courses which are recognised by NMC will be given permission to practice. So they are not considering about these State-recognised courses. And because of this issue, some of our students, whose exams are pending, they are fighting the case in Supreme Court and NMC is a party in the Supreme Court as well."
"And a few of my colleagues have also filed a case in the Supreme Court for pan-India recognition. We knew that this problem was going to arise sooner or later. Because when you are going for a single-nation, single registration then what about these students who are recognised by these different States?" he asked.
Dr. Trivedi explained that 10 CPS courses are recognised by the NMC and the rest of the 14 courses, including radiology, orthopaedics etc. are recognised by the State Medical Councils. He added, "With the coming of this particular rule, NMC has not made it clear how they will deal with these students who are recognised by the States. Students are still fighting a case for their examination to be conducted. We have given various representations to the NMC and the Central Government, and they are working on it. And despite that, the NMC comes out with such a draconian rule. How will you deal with these students? 2,300 students are still waiting for their exams, and then how will they register?"
Pointing out that CPS courses have been running since 1913, he mentioned that NMC, being the regulatory body, ahould have stopped the admissions, should have recognised the passed-out students as it has done for the IGNOU. "Being a regulatory body, your only work is not punishing the students, but to regularise- which they are not doing. They are just punishing students," he added.
"You [NMC] have been in existence since June 2020. You should have stopped the admissions. Why didn't you[NMC] stop at the first place? All these students got admission through the letter of the central government and state governments. All these courses were being conducted by State DMER departments. Now no one is ready to take responsibility for these kids. They are just being thrown under the bus. Their exams are pending, and you are coming out with such draconian laws that you will not be allowed to practice. Students are allowed to practice in 12 States; they are all legally correct, they are not under any medico-legal cases, and they are following all rules and regulations of the 12 States. Then how can they not follow rules in other States as well? In Half of India, they are allowed to practice. But in the other half, they are treated as plain MBBS students," he explained while highlighting the hardships faced by CPS graduates.
Speaking about the issue, Dr. Kumar added, "The way this whole scenario is developing is causing a great conundrum for the already practicing physicians, as it is a breach of contract for practicing in states where local medical councils have recognized us, and this puts the future of exam-awaiting 2500 students in peril. Even after repeated assurances from MoHFW, NMC puts a deaf ear to our pleas, jeopardizing 40000 practicing students and further pushing exam-barred students to the edge of their mental well-being. The most heart-wrenching part is that we, as educated nationalists and reasonable individuals, will not stoop to cry in front of Parliament, tarnishing our nation, and because of that, no one seems to be concerned with this matter, which has been brewing since 2017," he added.
The CPS Doctors also highlighted the recent decision of the NMC to grant retrospective recognition to IGNOU's PGDCC holders up to the last batch of 2013, bringing approximately 1,706 doctors into the recognised framework. Referring to this, CPS Doctors have questioned if a retrospective solution could be developed for a historical group of PGDCC doctors, why a similar solution cannot be found for thousands of already-qualified CPS specialists.
Finally, the CPS doctors referred to the Lok Sabha Committee on Subordinate Legislation raising serious concerns regarding procedural lapses in NMC regulations. Medical Dialogues had earlier reported that a Parliamentary Panel had mentioned that it was 'taken aback' to find that key regulations framed by the apex medical regulator were not vetted by the Ministry of Law and Justice.
Referring to the panel's report, the CPS doctors have questioned whether the new NMC draft has been adequately examined for its implications on legacy qualifications, pending judicial proceedings and thousands of doctors whose additional-qualification recognition remains unresolved.
They have stressed that the new NMC framework must not leave existing doctors in a regulatory vacuum. Referring to the draft, which aims to establish a national registration system for doctors, the CPS doctors have demanded a clear and fair national solution for doctors who have already obtained postgraduate qualifications but remain caught in State-wise recognition barriers.
Background:
Last year, the Bombay High Court passed an order cancelling the CPS recognition. Following this, the Directorate of Medical Education and Research stopped conducting further exams, leaving students who had already completed their courses but had not taken the exams in a difficult situation.
The Postgraduate Medical Education Board (PGMEB) of the National Medical Commission (NMC) derecognised all the courses offered by CPS on August 16, 2024, on the grounds of failure to comply with the regulatory mechanism under the National Medical Commission Act, 2019.
The Bombay High Court dismissed the plea filed by the College of Physicians and Surgeons (CPS) challenging the derecognition of many postgraduate diploma courses that were deleted from the schedule of the Maharashtra Medical Council (MMC), 1965. On the same day, the High Court bench had allowed a Public Interest Litigation (PIL) challenging permission given to CPS to conduct 10 additional PG courses. The PIL was filed before the High Court by a Mumbai-based doctor, Suhas Pingle.
Following this, the matter came for consideration before the Supreme Court in 2025. The Attorney General for India had informed the Apex Court that a viable solution would be arrived at to secure the future of students after the Bombay High Court upheld the derecognition of all PG medical courses offered by CPS Mumbai. Taking note of the issue, the Supreme Court on September 12 2025 requested the intervention of the Attorney General for India to arrive at a viable solution in this regard.
Later, the Central Government agreed before the Supreme Court to grant such students two final opportunities to clear their final examinations. This relief applied to 852 students of CPS Mumbai, and after clearing their final examinations, they would also be enrolled with the State and National Medical Councils.
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