Case Note & Summary
The Supreme Court set aside the Punjab and Haryana High Court’s order and directed admission of a PwD candidate to the MBBS course, emphasizing the need for functional assessment and rejecting discriminatory guidelines.
Constitution of India, 1950 — Article 14, Article 21, Article 41 — Rights of Persons with Disabilities Act, 2016 — National Medical Commission Guidelines, 2019 — Functional Assessment — Reasonable Accommodation — Inclusive Education — The Supreme Court ruled that the mechanical application of the 'both hands intact' requirement in the NMC guidelines is discriminatory and inconsistent with constitutional principles. The Court affirmed the importance of individual functional assessments and directed the NMC to revise its guidelines by the 2025-2026 academic year.
Subjects:
Constitution of India, Rights of Persons with Disabilities Act, National Medical Commission, functional assessment, reasonable accommodation, inclusive education, discriminatory guidelines, equal opportunity, medical education, assistive technologies.
Facts:
Nature of Litigation — The appellant challenged the denial of admission to the MBBS course based on a disability assessment that failed to evaluate functional capabilities.
Remedy Sought — The appellant sought a writ of certiorari to quash the disability certificate and requested a fresh assessment.
Reason for Filing — The disability assessment declared the appellant ineligible without providing reasons or conducting a functional assessment.
Prior Decisions — The Punjab and Haryana High Court dismissed the appellant’s writ petition, citing deference to expert opinions.
Issues:
a) Whether the 'both hands intact' requirement under the NMC guidelines violates the principles of equality and non-discrimination. b) Whether the functional assessment of candidates with disabilities should take precedence over mechanical application of disability percentages.
Submissions/Arguments:
Appellant: Argued for a functional assessment and reasonable accommodation, supported by the dissenting opinion of Dr. Satendra Singh.
Respondents: Defended the decision based on the existing NMC guidelines.
Decision:
The Supreme Court set aside the High Court’s order and directed the appellant’s admission to the Government Medical College, Sirohi, Rajasthan.
Ratio:
The Court held that the requirement for 'both hands intact' is outdated, discriminatory, and inconsistent with constitutional principles and the Rights of Persons with Disabilities Act, 2016. It emphasized the importance of individual assessments and reasonable accommodation.
Issue of Consideration
ANMOL VERSUS UNION OF INDIA & ORS.
