Case Note & Summary
The case pertains to Sarvepalli Radhakrishnan University and its affiliated medical college, R.K.D.F. Medical College Hospital and Research Centre, which was granted permission to admit 150 MBBS students annually from 2014-15. The college faced repeated inspections revealing deficiencies, leading to non-renewal of permission for the 2nd batch in 2015-16. After multiple court orders and inspections, the Oversight Committee granted conditional approval for the 2016-17 batch. However, a joint verification inspection in January 2017 found gross deficiencies, including low bed occupancy, lack of surgical operations, inflated clinical data, and shortage of faculty and residents. The Executive Committee of the Medical Council of India (MCI) recommended debarring the college for 2017-18 and 2018-19, which the Central Government accepted. The High Court of Madhya Pradesh allowed the college to provisionally admit students, but the Supreme Court directed a re-inspection. During the inspection for the 4th batch in September 2017, assessors were allegedly manhandled, and a subsequent inspection revealed severe deficiencies, including only 1.07% bed occupancy, no major surgeries, and inflated data. The MCI cancelled admissions and directed the college to discharge students. The college challenged this in the Supreme Court. The Court noted that the college had indulged in fraud by showing non-sick persons as patients. It directed a CBI-led inquiry into the correctness of the statistics and held that the college may face prosecution under Section 193 IPC. The Court cancelled the admissions but accommodated the students in other colleges, as they were not complicit. The Court upheld the MCI's decision to debar the college for two years.
Headnote
A) Medical Education - Renewal of Permission - Deficiencies - Regulation 8(3)(1)(b) of Establishment of Medical College Regulations, 1999 - Gross deficiencies in infrastructure, clinical material, teaching faculty, and bed occupancy found during inspection - College indulged in fraud by showing non-sick persons as patients - Held that cancellation of admission and debarment for two years is justified (Paras 1-13). B) Medical Education - Fraudulent Practices - Section 193 IPC - College submitted inflated data and fabricated patient records - Court directed CBI-led inquiry into correctness of statistics - Held that such conduct warrants prosecution under Section 193 IPC (Para 9). C) Medical Education - Student Accommodation - Equity - Students admitted provisionally subject to inspection result - Students not complicit in college's non-compliance - Held that students should be accommodated in other colleges to protect their interests (Para 8).
Issue of Consideration
Whether the Medical Council of India's decision to cancel admission of 4th batch MBBS students and debar the college for two years due to deficiencies and fraud is valid
Final Decision
The Supreme Court upheld the MCI's decision to cancel admission of the 4th batch MBBS students and debar the college for two academic years (2017-18 and 2018-19). The Court directed that the students be accommodated in other colleges. A CBI-led inquiry was ordered into the correctness of the statistics and material placed by the college, and the college may face prosecution under Section 193 IPC.
Law Points
- Regulation 8(3)(1)(b) of Establishment of Medical College Regulations
- 1999
- Section 193 IPC
- Oversight Committee directions
- conditional permission
- debarment for non-compliance
