Belated certificates cannot alone justify rejecting medical-college applications where comparable late submissions were accepted.

The petitioner-society applied on 2 February 2026 for permission to establish Jaipur Medical College and Hospital, Jaipur, with an annual intake of 100 MBBS students for the academic year 2026–27.

At the time of submitting the application, the petitioners did not possess the requisite Essentiality Certificate (“EC”) and Consent of Affiliation (“CoA”).

The National Medical Commission rejected the application on 10 June 2026 on that ground.

Before filing the first appeal, the petitioners obtained and uploaded both documents, but the first appellate authority nevertheless rejected the appeal for want of the same documents.

Relying on As Jagannath Gupta Institute of Medical Sciences and Hospital v. Union of India & Ors., W.P.(C) 17090/2025, the petitioners sought, inter alia, consideration of the subsequently obtained certificates, inspection of the college, and adjudication of their second appeal.

1. Whether the Essentiality Certificate and Consent of Affiliation, obtained after submission of the original application but before the first appeal, could be taken on record and considered by the authorities.

2. Whether the respondents were required to conduct an inspection of the petitioner-institution and decide the pending second appeal in accordance with law.

3. Whether rejection of the application solely for non-submission of the two documents at the initial stage was arbitrary or inconsistent with the treatment afforded to similarly situated institutions.

The petition was instituted under Article 226 of the Constitution of India.

The Court considered the statutory scheme under Sections 28 and 29 of the National Medical Commission Act, 2019, including the requirements relating to processing of applications, rectification of deficiencies, appeals, and assessment of medical colleges.

The Court relied principally on As Jagannath Gupta Institute of Medical Sciences and Hospital v. Union of India & Ors., where it was held that acceptance of Essentiality Certificates after submission of the original applications, in some cases, undermined the respondents’ contention that such certificates must invariably accompany the application; selective acceptance or rejection without an objective and rational basis could violate equality, administrative fairness, transparency, and non-arbitrariness.

The Court noted that both the EC and CoA had been obtained before the first appeal was filed, yet the appellate authority rejected the appeal solely because the documents were not available with the original application.

Applying the reasoning in As Jagannath Gupta, the Court held that there was no justification to adopt a contrary approach where the authorities had accepted such documents at later stages in other cases and had permitted inspection during the pendency of appellate proceedings.

The differential treatment, absent any demonstrated objective criterion, raised concerns of arbitrariness and unequal administrative treatment.

Accordingly, the Court directed consideration of the second appeal and ordered an inspection of the petitioner-institution.

It further directed Respondents Nos. 1 to 3 to conduct an inspection of the petitioner-institution within one week from the date of the order.

In view of these directions, the petitioners’ grievance was treated as satisfied; their counsel did not press the writ petition, which was accordingly disposed of along with the pending applications.