SARASWATI EDUCATIONAL CHARITABLE TRUST Vs. UNION OF INDIA

CITATION	2021 SCC ONLINE SC 89
DATE OF JUDGEMENT	24th February, 2021
COURT	Supreme Court of India
PETITIONER	Saraswati Educational Charitable Trust & Anr.
RESPONDENT	Union of India & Ors.
BENCH	L. Nageswara Rao S. Ravindra Bhat, JJ.

INTRODUCTION

The case revolves around the controversial admission process carried out by Saraswati Medical College for the academic year 2017-2018. The institution admitted 132 students without the due process mandated by the Medical Council of India (MCI) Regulations. Consequently, this action led to two writ petitions challenging the MCI’s notice demanding the discharge of these students. The main focus of the Supreme Court was to decide on the legality of the admissions made by the college, the liability of the students, and the penalties applicable to the college for contravening established admission procedures.

FACTS OF THE CASE

1. Saraswati Medical College, established by Saraswati Educational Charitable Trust in 2016, applied for renewal of permission to admit 150 students for the academic year 2017-2018. The Medical Council of India (MCI) conducted an inspection of the college in November 2016 and subsequently denied the renewal of permission by an order dated August 10, 2017. The denial was challenged by the college in Writ Petition No. 515 of 2017, resulting in the court directing the respondents to allow the college to participate in the counseling process and extend the admission deadline to September 5, 2017.
2. The college requested the Director General of Medical Education (DGME) for a list of students from the NEET 2017 merit list to fill the seats by the extended deadline. On September 4, 2017, the DGME informed eligible students to register for admission to the college. Out of 735 registered students, a list of 150 students was forwarded to the college, but only 9 completed their admission formalities by September 5, 2017.
3. Without waiting for further response from DGME, the college issued an urgent notice to the remaining 735 students at 7:32 p.m. on September 5, 2017, to complete admissions based on merit by midnight. Consequently, the college admitted 132 students who were not part of the original 150-student list forwarded by DGME.
4. The Medical Council of India issued a notice on September 29, 2017, instructing the college to discharge the 132 students, citing violations of the MCI Regulations on Graduate Medical Education, 1997. Saraswati Educational Charitable Trust filed Writ Petition (C) No. 40 of 2018 challenging the MCI notice, while Writ Petition (C) No. 291 of 2019 was filed by 71 affected students seeking permission to continue their studies.
5. The students were allowed to write their first-year MBBS examinations provisionally, with the declaration of results subject to the court’s final decision. Upon provisional clearance, 126 students moved to the second year, and an application was made to permit them to appear for the second-year examinations.

ISSUES RAISED 

1. Whether the admission of 132 students by Saraswati Medical College was in compliance with the MCI Regulations on Graduate Medical Education, 1997?
2. Whether the MCI’s notice directing the discharge of the 132 students was justified?
3. Whether the students, being unaware of any procedural irregularities, should be penalized by losing their academic progress?
4. What should be the consequence for the college for violating the prescribed admission procedures?

CONTENTIONS OF THE PETITIONER

The college argued that they admitted students based on merit from a list of 735 candidates who registered in response to the notice issued by the third respondent on September 4, 2017, due to the urgency of the situation. They claimed that the DGME failed to provide a sufficient number of students on time, forcing the college to proceed with available candidates. The college contended that the third respondent’s lethargic response led to the situation, as the DGME had only provided a list of 150 students on the last admission day. The college insisted that the admissions were transparent and based on merit, with no complaints from students regarding discrimination. The college maintained that they followed the process according to the circumstances and adhered to the court’s directives, hence were not in violation of any regulation.

CONTENTIONS OF THE RESPONDENT

The MCI emphasized that the college violated Regulation 5A of the MCI Regulations, which mandates admissions through centralized counseling based on NEET merit lists provided by the DGME. They argued that the college acted independently without obtaining candidates through the designated process, constituting a blatant violation. The respondents contended that the college should have sought an extension of time from the court or requested additional allotments from DGME rather than admitting students unilaterally. They stressed that the college’s actions were against the law, and the admissions lacked legal backing, thereby requiring annulment. The MCI argued that students were aware their admissions were not legally sanctioned since their names were not on the DGME-provided list. They maintained that the students knowingly participated in an unlawful admission process. The MCI insisted that Saraswati Medical College should face stringent penalties to deter similar violations by other institutions in the future.

JUDGMENT

The Supreme Court dismissed the writ petitions filed by Saraswati Educational Charitable Trust and the 71 students. The court held that the college’s admission of 132 students for the academic year 2017-2018 was entirely contrary to the MCI Regulations and therefore invalid. However, acknowledging the students’ advancement in their medical education, the court allowed them to complete their MBBS courses under specific conditions. The court directed that the students be allowed to continue their studies and permitted them to appear for their second-year examinations. The court emphasized that this decision was an exception, considering the students’ academic progress. As a form of community restitution, the court ordered the students to perform two years of community service after completing their MBBS degree, with the National Medical Commission tasked with determining the details and modalities. The court imposed a financial penalty of Rupees Five Crores on Saraswati Medical College, payable within eight weeks, for intentional violation of admission regulations. The court specified that the college could not recover this penalty from the students in any manner. The court directed the National Medical Commission to establish a trust to manage the five-crore penalty, aimed at providing financial assistance to needy medical students in Uttar Pradesh. The trust was to include representatives from the Accountant General of Uttar Pradesh, an eminent educationist, and a state government representative, with an action report required within 12 weeks. The court explicitly stated that this decision would not set a precedent for similar future cases, given its reliance on the specific facts and circumstances at hand.

ANALYSIS 

The judgment by the Supreme Court balances the rigid adherence to regulatory standards with the recognition of human factors and potential life impacts on the students involved. While emphasizing strict compliance with the MCI Regulations, the court acknowledged the educational progress of the students who were victims of procedural lapses rather than active perpetrators. This consideration for the students’ future reflects a judicial understanding that aligns the rule of law with equitable treatment. The court reinforced the significance of adhering to the MCI Regulations, which serve to standardize and maintain the quality of medical education. The court’s decision discourages any educational institution from bypassing these standards for expedient admissions. Saraswati Medical College’s failure to comply with the established procedures underscored the importance of institutional responsibility in adhering to educational norms. The court’s decision underlined the accountability of educational institutions in upholding legal standards, highlighting that regulatory violations cannot be overlooked even if conducted in good faith or under pressing circumstances. By permitting the students to continue their education, the court acknowledged the principle of educational equity and the potential lifelong impact of academic disruptions. However, the court also held the students accountable to an extent by mandating community service, thereby instilling a sense of civic duty and restitution. The substantial financial penalty imposed on the college serves as a strong deterrent against future regulatory violations by educational institutions. It communicates the judiciary’s firm stance against procedural malpractice while also providing resources for socially beneficial purposes through the trust fund. The community service requirement for students exemplifies the court’s creative approach to justice, blending punitive measures with opportunities for social contribution. This not only provides a corrective experience for the students but also leverages their future professional capabilities for the public good, particularly in underserved areas. While the judgment explicitly states that it should not be treated as a precedent, it may still influence future cases involving regulatory breaches in educational institutions. The emphasis on balancing regulatory adherence with consideration for students’ futures might inform judicial decisions where academic progress and potential harm to students are at stake.

CONCLUSION

The Supreme Court’s decision in *Saraswati Educational Charitable Trust v. Medical Council of India* is a landmark case that highlights the complexities involved in regulatory compliance within the educational sector. The court adeptly navigated the balance between enforcing strict adherence to regulations and recognizing the unforeseen impacts on innocent students caught in administrative violations. The case reinforces the accountability of educational institutions in following mandated procedures and the consequences of bypassing regulatory standards. The imposition of a hefty financial penalty on Saraswati Medical College underscores the judiciary’s intolerance for procedural breaches and emphasizes the importance of institutional integrity in the educational domain. Despite the college’s regulatory violations, the court’s decision reflects a compassionate stance towards students who were unknowingly caught in procedural discrepancies. By allowing students to complete their MBBS course under the condition of community service, the court balanced legal enforcement with equitable treatment, acknowledging the significant investment students had made in their education. The ruling sets a strong deterrent effect, warning other educational institutions against similar violations and reinforcing the need for compliance with established admission processes. This deterrence is crucial for maintaining the quality and credibility of medical education in India. The introduction of community service for students and the establishment of a trust to utilize the penalty funds exemplify the court’s innovative approach in crafting a remedy that not only addresses the specific case at hand but also contributes to the broader societal good. These measures underline the judiciary’s role in promoting ethical conduct while considering the broader impact of legal decisions. In conclusion, the case serves as a critical reminder of the intricate balance between legal compliance, institutional responsibility, and individual equity. It underscores the judiciary’s role in ensuring that educational institutions uphold their legal obligations while simultaneously safeguarding the interests of students who rely on these institutions for their academic and professional futures. The judgment not only addresses the immediate legal issues but also contributes to the ongoing discourse on educational governance and regulatory adherence, making it a significant case in the context of Indian legal and educational jurisprudence.

REFERENCES

1. https://indiankanoon.org/doc/56334561/#:~:text=On%20receipt%20of%20information%20about,students%20who%20were%20admitted%20in
2. https://main.sci.gov.in/supremecourt/2018/1406/1406_2018_31_1501_26545_Judgement_24-Feb-2021.pdf

This article is written by Riya Singla, student of Himachal Pradesh National Law University, Shimla (HPNLU); Intern at Legal Vidhiya.

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