Supreme Court Dismisses Petition Challenging NEET-PG 2022 Internship Deadline — Upholds Regulatory Authority's Decision. The court ruled that the extension of the cut-off date was a policy decision within the executive's domain and not arbitrary.

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Case Note & Summary

The Supreme Court addressed a petition filed under Article 32 of the Constitution by doctors aspiring to appear for NEET-PG 2022, challenging the deadline for completing their internships. The National Board of Examination had set the cut-off date for internship completion as 31 May 2022, which was later extended to 31 July 2022. The petitioners argued that this extension still disadvantaged students from certain states who began their internships later due to Covid-related duties. The court noted that while the extension posed challenges for some students, it was ultimately a policy decision within the executive's purview. The court referenced previous judgments emphasizing the need for judicial restraint in academic matters and the importance of maintaining educational schedules. The court dismissed the petition, stating that extending the cut-off further would disrupt the examination timeline and affect students who met the revised deadline. The court also rejected the argument to count Covid duty time towards internship requirements, asserting that such decisions should not be made by the judiciary. The petition was dismissed, and any pending applications were disposed of.

Headnote

A) Constitutional Law - Article 32 - Judicial Review of Policy Decisions - Courts should defer to the executive's discretion in setting eligibility criteria for examinations - Article 32 of the Constitution, 1950 - The court emphasized that determining cut-off dates is within the executive's domain and should not be interfered with unless shown to be arbitrary or discriminatory. The court dismissed the petition challenging the cut-off date extension, recognizing the need for adherence to the educational schedule (Paras 9-14).

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Issue of Consideration

Whether the extension of the internship completion deadline for NEET-PG 2022 was arbitrary and if the period spent on Covid duties should count towards internship requirements.

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Final Decision

The Supreme Court dismissed the petition, stating that the extension of the cut-off date was a policy decision within the executive's domain and not arbitrary. The court emphasized the need to maintain the educational schedule and rejected the inclusion of Covid duty time towards internship requirements.

Law Points

  • Article 32 of the Constitution
  • eligibility criteria
  • judicial review
  • academic policy
  • cut-off date
  • executive discretion
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Case Details

2022 LawText (SC) (04) 171

Writ Petition (C) No. 208 of 2022

2022-04-05

Dr Dhananjaya Y Chandrachud, Surya Kant, Bela M. Trivedi

Gopal Sankaranarayanan, Aishwarya Bhati

Shikhar & Anr.

National Board of Examination & Ors.

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Nature of Litigation

Challenge to the cut-off date for internship completion for NEET-PG 2022.

Remedy Sought

Petitioners sought an extension of the internship cut-off date.

Filing Reason

Petitioners argued that the cut-off date disadvantaged students from states with delayed internships due to Covid duties.

Previous Decisions

The court previously allowed petitioners to submit representations regarding the hardship faced.

Issues

Whether the extension of the internship completion deadline was arbitrary. Whether the period spent on Covid duties should count towards internship requirements.

Submissions/Arguments

Petitioners argued for further extension of the cut-off date due to delayed internships. Respondents highlighted the disruption to the examination schedule if the cut-off were extended further.

Ratio Decidendi

The determination of cut-off dates lies within the executive's discretion, and courts should not interfere unless the criteria are shown to be arbitrary or discriminatory.

Judgment Excerpts

The issue which has been raised by the petitioners requires a determination of facts bearing on the position in different parts of the country. The court emphasized that determining cut-off dates is within the executive's domain and should not be interfered with unless shown to be arbitrary or discriminatory. An extension of the cut-off any further would result in the disruption of the educational schedule.

Procedural History

The petition was filed under Article 32 of the Constitution challenging the cut-off date for internship completion for NEET-PG 2022. The court allowed petitioners to submit representations regarding their hardships, which led to the extension of the cut-off date from 31 May 2022 to 31 July 2022.

Acts & Sections

  • Constitution of India: Article 32
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