Academic duties and postgraduate thesis guidance cannot be arbitrarily denied to eligible faculty members without due process.

The petitioner, a Designated Professor in the Department of Orthopedics at Gajra Raja Medical College, Gwalior, challenged the order dated 04.05.2026 issued by the Head of Department (Respondent No. 5).

This order excluded the petitioner’s name from the list of faculty members allotted as thesis guides for postgraduate M.S. (Orthopedics) students.

The petitioner alleged that this exclusion was retaliatory, following his success in previous litigation (W.P. No. 7729/2026) against the college.

Despite being senior to several faculty members who were allotted students, and having no pending disciplinary proceedings, the petitioner was bypassed without a show-cause notice or hearing.

1. Whether the exclusion of a Designated Professor from the list of postgraduate thesis guides without assigning reasons or providing a hearing is legally sustainable

2. Whether the denial of academic responsibilities, such as thesis guidance, prejudicially affects a faculty member's promotional prospects and academic career

National Medical Commission (NMC) Minimum Standard Requirements for Postgraduate Courses, 2023 (as amended on 20.02.2026), which dictates a specific faculty-to-student ratio for thesis guidance, allowing a Professor in a government college to guide up to three students.

Principle of Natural Justice, specifically the requirement of a show-cause notice or opportunity of hearing before passing an order that adversely affects a person's professional status or future prospects.

Presumption of due service of notice under Rule 11(1) of Chapter XV of the M.P. High Court Rules read with Section 27 of the General Clauses Act.

The court found that the petitioner, as a Designated Professor, was fully eligible under NMC regulations to supervise postgraduate students.

It noted a significant procedural lapse: the respondents excluded the petitioner while assigning students to juniors—some of whom were the petitioner's former students—without providing any justification, restraining order, or disciplinary grounds.

The court reasoned that since thesis guidance is a mandatory parameter for Annual Confidential Reports (ACR) and critical for future promotions to posts like Dean, the exclusion constituted a "colourable exercise of power" that directly harmed the petitioner’s academic career.

As the respondents failed to appear despite being served, the petitioner's claims regarding seniority and mala fide intentions remained uncontroverted.

It held that the petitioner is entitled to guide postgraduate students as per his designation and seniority under NMC guidelines.

The Court directed the respondents to include the petitioner’s name in the order dated 04.05.2026 and allot him students for thesis guidance in accordance with the prescribed ratios. Compliance was ordered to be completed on or before 31.07.2026.