Case Title: Anmol vs. Union of India & Ors.
Court: Supreme Court of India
Citation: 2025 INSC 256
Bench: B.R. Gavai and Justice K.V. Viswanathan
Date of Judgment: February 21, 2025
FACTS OF THE CASE
The case in question is related to Anmol, who has locomotor and speech disability and was very recently denied admission into the MBBS course in the Persons with Disabilities (PwD) quota even after securing a position much above the cut-off in the OBC-PwD category. His writ petition was rejected by the Punjab and Haryana High Court with the simple comments that courts cannot substitute the opinions of expert medical boards. Anmol then asked to go to the Supreme Court, which granted him temporary relief on December 12, 2024, directing his admission to Government Medical College, Sirohi, Rajasthan, until the final order. The Court asked that there be an independent assessment by AIIMS, New Delhi, with Dr. Satendra Singh as an expert.
KEY ISSUES
- Does the disability determine eligibility, or should functional assessment play a role in admission to medical courses?
- To also understand if the National Medical Commission (NMC) guidelines are aligned with the principles of equal opportunity for PwD candidates?
- Did the Punjab and Haryana High Court do the right thing by rejecting Anmol’s application with a detailed review?
- Is it required by different medical boards to revise their disability assessment criteria. It would mean that they would have to focus on functional competency rather than rigid physical requirements?
LEGAL PROVISIONS INVOLVED
- Rights of Persons with Disabilities (RPwD) Act, 2016: This act in the is very important to ensure that there is equal access to education and accommodation for people with disabilities.
- National Medical Commission (NMC) Guidelines: Criteria for eligibility of candidates with disabilities in medical education.
- Article 14 of the Indian Constitution: This article has guaranteed the right to equality which prevents random discrimination.
- Article 41 of the Indian Constitution: Article 41 is a directive. It is regarding how the state is obligated to give education and employment of persons with disabilities.
- Omkar Ramchandra Gond vs. Union of India (2024): Mandated revision of NMC disability guidelines.
- Om Rathod vs. Director General of Health Services (2024): Directed functional assessment over mere disability quantification.
ARGUMENTS
Petitioner’s Arguments:
- Functional Assessment was not done for Anmol: The Chandigarh medical board ignored Anmol’s ability to perform essential medical tasks, and they relied on a percentage of disability that Anmol had.
- Violation of RPwD Act, 2016: This rejection also was against the RPwD act because Anmol was not given accommodation even though he scored extremely high marks and could perform medical procedures with assistive technologies which are available in the hospital.
- Independent Assessment : The plaintiff argued that the investigation that was started by the court also proved that Anmol could complete his MBBS with basic accommodations.
Respondent’s Arguments:
- NMC Guidelines: The medical board followed the existing regulations which were set by the NMC and it allows the Board to disqualify candidates with certain disabilities.
- Role of Courts in Expert Medical Decisions: The High Court ruled in favour of the board because it was enforced that the courts cannot be involved in expert medical assessments.
- Patient Safety Considerations: The respondents argued that certain physical disabilities might compromise patient care and safety, justifying the restrictions in medical admissions.
ANALYSIS
The Supreme Court of India, changed the decision of the Punjab and Haryana High Court and ended up ruling that the disability assessment guidelines violate different constitutional principles. The Court also enforced the idea that functional ability and reasonable accommodation must be a priority over any kind of disability percentages. The NMC Guidelines require urgent revision as the “both hands intact” requirement discriminates against candidates who can otherwise perform medical tasks with assistive technologies. The Court found that there was a failure to conduct a functional assessment of Anmol and it was discriminatory for him. The expert assessment by Dr. Satendra Singh, who was appointed by the court also confirmed that Anmol could complete medical training successfully with basic accommodations. This analysis ended up proving that not giving him admission violated his rights under the RPwD Act, 2016. The ruling proved that courts have a duty to prevent bad-faith application of regulations, ensuring that PwD candidates receive fair opportunities based on their functional abilities rather than outdated medical norms.
JUDGMENT
- The Punjab and Haryana High Court’s ruling was set aside by the Supreme Court of India.
- Anmol’s admission to the Government Medical College in Sirohi was confirmed.
- NMC was directed to revise disability assessment guidelines by March 2025.
- Case listed for monitoring of NMC guideline revision on March 3, 2025.
CONCLUSION
The Supreme Court ruling in Anmol vs. Union of India & Ors. is a landmark precedent for medical education disability rights. By abandoning the present NMC guidelines, the Court has made sure that the doctrine of reasonable accommodation which is meant to ensure PwD candidates are extended fair opportunities based on their functional abilities. This decision is necessary to talk about reform of admission policies in medicine to align them with the constitution. It also ensures judicial oversight that protects rights of PwD candidates from being denied based on discriminatory and old regulations.
“PRIME LEGAL is a full-service law firm that has won a National Award and has more
than 20 years of experience in an array of sectors and practice areas. Prime legal falls
into the category of best law firm, best lawyer, best family lawyer, best divorce lawyer,
best divorce law firm, best criminal lawyer, best criminal law firm, best consumer
lawyer, best civil lawyer.”
WRITTEN BY TANMAYEE VELLORE RAGHUNANDAN
