MP High Court slams MPPSC for rejecting doctors over unstated PG Registration

Bhopal: Reiterating that recruitment rules cannot be changed midway, the Madhya Pradesh High Court ruled that the Madhya Pradesh Public Service Commission (MPPSC) cannot reject qualified medical practitioners by imposing a postgraduate additional registration requirement in the recruitment process that was not mentioned in the official advertisement.

The court noted that several candidates were rejected during the recruitment process for medical officers and specialist doctors because they did not have a postgraduate additional registration certificate, which was treated as mandatory. However, the advertisement did not clearly mention any such requirement. Even candidates who obtained the registration later were also rejected by the commission.

Supporting the petitioners, the court clarified that eligibility conditions must be clearly mentioned upfront in the recruitment advertisement notification and cannot be introduced later in the selection process.

A division bench of the High Court headed by Justice Jai Kumar Pillai observed, "Introducing an unstated eligibility requirement after the recruitment process had begun amounts to altering the rules of the selection process. Such changes violate principles of fairness and transparency and infringe on candidates’ rights under Articles 14 and 16 of the Constitution of India. If the MPPSC intended to make the postgraduate additional registration an essential condition, it should have clearly stated so in the advertisement."

Also read- NEET PG: MP HC issues notice on plea agaisnt rule barring non-state MBBS graduates

As per Medbound Times media report, the ruling came while the bench was hearing a batch of writ petitions filed by qualified doctors. These doctors had applied for the posts of Medical Officer (Grade-I) and Specialist Doctors under the Public Health and Medical Education Department through MPPSC.

As per the recruitment advertisement, candidates were required to have a recognised postgraduate degree in the relevant medical speciality and permanent registration with the State Medical Council. However, there was no mention of a separate “Post Graduate Additional Registration Certificate” being mandatory by any cut-off date.

Despite meeting the qualifications and applying within the prescribed period, several candidates were later excluded at the document verification stage or after provisional results. MPPSC treated the separate postgraduate additional registration as a mandatory condition and rejected candidates who had obtained it after the cut-off date of April 21, 2025.

The petitioners argued that this additional requirement was never mentioned in the original advertisement or any corrigendum. They also pointed out that delays in result declarations and administrative procedures were beyond their control and affected their ability to obtain the additional registration earlier.

Agreeing with the doctors, the High Court observed that adding new conditions midway in the recruitment process amounts to changing the rules after the recruitment process has already begun. The court said such changes violate principles of fairness and transparency and infringe on candidates’ rights under Articles 14 and 16 of the Constitution of India.

The court further held that if the MPPSC intended to make the postgraduate additional registration an essential condition, it should have clearly stated so in the advertisement. The bench also rejected reliance on a Government Gazette notification to add eligibility conditions not expressly mentioned in the recruitment notification.

Allowing the petitions, the High Court directed the competent authority to check whether the candidates had the required recognised postgraduate qualification and whether their results were declared on or before April 21, 2025.

"If these conditions are met, the candidates should not be excluded from the recruitment process for not having the additional registration by the cut-off date," said the Bench.

Also read- 'Unconstitutional': MP HC strikes down rule limiting PG medical seats to in-state MBBS graduates