
Constitution of India, 1950 — Article 14 — Article 21 — Article 41 — Right to Equality — Right to Life — Directive Principles of State Policy — Court upheld the right to education and inclusive education for persons with disabilities, emphasizing fairness and equity in admission procedures (Para 10, 11, 12).
Rights of Persons with Disabilities Act, 2016 — Section 2(m) — Inclusive Education — Court interpreted the statutory backing for inclusive education and directed assessment of functional competency rather than mere quantification of disability (Para 9, 10).
Medical Council of India Regulations — NEET-UG Admission Guidelines — Disability Certification — The Court ruled that the Disability Certification Medical Board’s opinion on a candidate’s functional competency must be decisive in determining eligibility for medical education (Para 8, 9).
The Court held that: a) Functional competency, as assessed by the NEET Disability Certification Medical Board, must govern eligibility for medical education. b) Quantification of disability per se cannot disqualify a candidate from pursuing the course of their choice.
Nature of the Litigation: Writ petition filed by a student with 58% multiple disabilities and speech disability exceeding 40%, challenging disqualification from admission to the MBBS course.
Who Asked the Court and for What Remedy: Petitioner: Suyash Suryakant Patil — Sought restoration of admission to the MBBS course under the Persons with Disabilities (PwD) category.
Reason for Filing the Case: Petitioner’s admission to Government Medical College, Jalna, was cancelled due to his disability exceeding the 40% benchmark, despite being found functionally competent.
What Had Already Been Decided: Interim relief was granted, permitting provisional admission to the MBBS course, subject to the final outcome and assessment by the Disability Certification Medical Board.
Issues:
a) Whether the petitioner was eligible for the MBBS course despite exceeding the 40% disability benchmark. b) Whether the petitioner was entitled to claim PwD reservation.
Submissions/Arguments:
Petitioner’s Counsel — Cited Supreme Court decisions emphasizing functional competency over quantified disability. Respondents’ Counsel — Argued that the petitioner’s disability exceeded the benchmark and disqualified him from PwD reservation.
Ratio:
The principle of inclusive education mandates that assessment focus on a candidate’s ability to pursue the course rather than rigid adherence to quantified disability thresholds (Para 9, 10, 12).
Subjects:
Constitutional Rights — Inclusive Education — Functional Competency — PwD Reservation — Medical Education — Disability Certification.
Case Title: Suyash Suryakant Patil Versus National Medical Commission Through Its Secretary And Ors.
Citation: 2025 LawText (BOM) (2) 214
Case Number: WRIT PETITION NO.13072 OF 2024
Date of Decision: 2025-02-21