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For Admission in MBBS, Prior Knowledge of Senior Secondary Level Biology Is Essential: Supreme Court

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The Supreme Court in a judgment dated 16 February 2021 observed that to get admission in the course of MBBS, it was essential that the candidate should have prior knowledge in biology or biological science of Senior Secondary Level. The knowledge should be in both theory and practical.

Facts of the case

In the present case, the Respondent was a student, who had applied for admission in the MBBS/BDS course in the management quota for the NRI candidates during the academic year 2020-2021. In the list published by the University, the name of the Respondent student was there. The University clarified in that list that the student had not furnished any kind of proof of her studying of subjects of biological science in her qualifying examination (10+2 or equivalent).

The student candidate also secured the letter from the Consulate General of India, New York which stated that the student had completed her 12th grade from the Conrad High School, West Hartford, Connecticut. The letter further stated that her 12th grade was equivalent to Pre-University (Two year Course) New Intermediate University and the Board Examination Certificate of the 12th standard of India. 

When on 23 December 2020, the University issued a notice, for the admission in MBBS/BDS course in the management quota, seeking web options for 2nd round of counselling for the academic year 2020-2021, the student approached the High Court on the very next day. Here, the Respondent relied on the certificate issued by the Telangana State Board of Intermediate Education along with the Certificate issued by the Conrad High School. After taking this certificate into account, issued by the Telangana State Board of Intermediate Education, the High court of Telangana held that the refusal on the part of the university was illegal. Aggrieved by this Order, the University approached the Supreme Court. 

Pleadings in the Court

The learned counsel on behalf of the Appellant contended that the Medical Council of India Regulation on Graduate Medical Education, Regulation 4(2) laid down the emphasis on the condition that the student should have complete schooling in those subjects in each of the concerned years of the school life, i.e, 11th and 12th and should have passed the Senior Secondary level with English as a subject as well, along with the condition that the qualification must be equivalent to the qualification for 10+2 or intermediate science examination held at Indian University.

On the other hand, the learned Senior Counsel on behalf of the student argued that it was rightly said in the impugned judgment that the candidate held equivalent qualifications and was eligible for consideration for a medical UG/MBBS course.

Court’s Observation

The bench of the Supreme Court comprising Justice L. Nageshawar Rao and S. Ravindra Bhatt observed that it was an essential qualification to have prior knowledge of both the theoretical as well practical in biology and biological science of the senior secondary level to get admission in the MBBS/BDS course.

Furthermore, it was noted that qualification equivalence was not merely at the level of a prerequisite of 10+2, i.e. that the applicant should have passed an examination equal to an intermediate scientific examination at an Indian University. In addition to this provision, in the examination where the applicant was tested in Physics, Chemistry, and Biology, Regulation 4(2)(f) included standard and scope equivalence, including practical testing in these subjects along with English.

Court’s Judgement

In this case, the Court set aside the impugned judgment of the High Court and said that it could not be sustained. While setting aside the Order, the Court said that to be successful, the applicant should produce clear and categorical material to demonstrate that in all the stipulated subjects she underwent the requisite years of study. The Court considered that such requirements were necessary, provided that the course in question, i.e. MBBS, required prior experience, both theoretical and practical, of senior secondary level in biology or biological sciences, primarily if not predominantly.

Case: Kaloji Narayana Rao University of Health Sciences vs. Srikeerti Reddi Pingle [Civil Appeal No. 390 of 2021]

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