Courts will not restore an expired academic-session intake after admissions close amid recorded regulatory deficiencies.

The petitioners, Nezamia Unani Medical College and Hospital and its authorised representative, challenged the Ministry of Ayush’s order dated 20 November 2025 in Second Appeal No. F.No. O-14014/5/2025-EP-I.

The Ministry had rejected the petitioners’ second appeal and upheld the National Commission for Indian System of Medicine’s order dated 16 October 2025, which affirmed the Medical Assessment and Rating Board’s decision dated 29 August 2025 reducing the college’s approved BUMS intake for the academic session 2025–26 from 40 seats to 28 seats.

The respondents asserted that the reduction was made under Section 28(1)(f) of the National Commission for Indian System of Medicine Act, 2020, after notice, hearing, inspection, and consideration of deficiencies, including failure to implement the Aadhaar Enabled Biometric Attendance System for the relevant academic year.

The admission period for the 2025–26 session had expired on 31 January 2026.

Whether the respondents were legally justified in reducing the petitioner institution’s BUMS intake capacity for the academic session 2025–26 under Section 28(1)(f) of the NCISM Act, 2020.

Whether the reduction of seats was vitiated by denial of notice, opportunity to rectify deficiencies, or adequate hearing before the inspection and appellate authorities.

Whether any effective relief could be granted after the admission period for the 2025–26 academic session had expired.

The Court applied Section 28(1)(f) of the National Commission for Indian System of Medicine Act, 2020, under which the competent regulatory authority may take appropriate action concerning an institution’s compliance and permitted intake capacity.

It applied the principles of natural justice, including the requirement of notice and a meaningful opportunity of hearing before an adverse regulatory decision is taken.

The Court also considered Royal Medical Trust v. Union of India, (2017) 16 SCC 605, relied upon by the petitioners in support of the requirement that institutions be afforded an opportunity to rectify deficiencies before adverse action is taken.

Regulatory decisions based on inspection findings and recorded deficiencies will not ordinarily be interfered with in writ jurisdiction where the decision-making process is shown to be proper and the relief has become practically ineffective.

The Court noted that the respondents’ decision was confined to the 2025–26 academic session and was based on the inspection report, recorded deficiencies, and the institution’s failure to implement the Aadhaar Enabled Biometric Attendance System.

The respondents maintained that notice and an opportunity of hearing had been provided, and the Court found no cogent reason to disbelieve or interfere with that regulatory process.

Even assuming a challenge to the reduction remained arguable, restoration of seats was no longer capable of granting effective relief because the admission period had ended in January 2026, more than eight months before the judgment.

The Court therefore declined to substitute its assessment for that of the specialised regulatory authorities or to disturb the session-specific reduction.

However, in the interests of justice, it directed the NCISM to conduct a fresh inspection of the petitioner institution before the next academic session in accordance with the NCISM Act, 2020, and to take an appropriate decision thereafter.