Case Note & Summary
The petitioners, four medical students, appeared for the General Medicine practical examination conducted by Rajiv Gandhi University of Health Sciences in January 2020. The University appointed three examiners to assess their practical answer books, and the marks were not averaged. The petitioners contended that this violated Regulation 13 of the Graduate Medical Education Regulations, 1997, which requires that practical examinations be assessed by at least two examiners (one internal and one external) and that the marks be averaged. The High Court of Karnataka, in a writ petition under Articles 226 and 227 of the Constitution, examined the regulation and found that the University's action was indeed contrary to the statutory mandate. The court quashed the valuation and directed the University to revalue the answer book in accordance with Regulation 13, ensuring that the marks are averaged. The court also noted that the Medical Council of India and the Karnataka Medical Council supported the petitioners' interpretation. The decision emphasizes the importance of adhering to statutory regulations in medical education to ensure fairness and uniformity.
Headnote
A) Medical Education - Practical Examination Valuation - Regulation 13 of Graduate Medical Education Regulations, 1997 - The petitioners challenged the valuation of their practical answer book in General Medicine by three examiners appointed by the University, contending that the marks were not averaged as required by Regulation 13. The court held that Regulation 13 mandates that practical examinations be assessed by at least two examiners, one internal and one external, and the marks must be averaged. The appointment of three examiners and the failure to average the marks violated the regulation, rendering the valuation invalid. (Paras 1-10) B) Writ Jurisdiction - Quashing of Examination Valuation - Articles 226 and 227 of the Constitution of India - The court exercised its writ jurisdiction to quash the valuation of the practical answer book, as the University's action was contrary to the statutory regulations. The court directed the University to revalue the answer book in accordance with Regulation 13. (Paras 1-10)
Issue of Consideration
Whether the valuation of the practical answer book in General Medicine by three examiners, without averaging the marks as required under Regulation 13 of the Graduate Medical Education Regulations, 1997, is valid
Final Decision
The writ petition is allowed. The valuation of the practical answer book of the petitioners in General Medicine examination conducted in January 2020 is quashed. The respondent University is directed to revalue the answer book in accordance with Regulation 13 of the Graduate Medical Education Regulations, 1997, by appointing two examiners (one internal and one external) and averaging the marks.
Law Points
- Regulation 13 of Graduate Medical Education Regulations
- 1997 mandates that practical examinations in medical courses must be assessed by at least two examiners
- one internal and one external
- and the marks must be averaged
- any deviation renders the valuation invalid
