Facts
The petitioner was allotted an MD Microbiology seat at AIIMS Rishikesh in the Open Round of INI-CET counselling for the July 2026 session, but was denied admission because he did not submit his original academic documents by 31 August 2026.
Source reference: pp. 2–3The documents were being retained by Index Medical College, Indore, in connection with the petitioner’s bond under a Madhya Pradesh government scheme, which required rural or remote service or payment of a penalty.
Source reference: p. 2The petitioner had submitted self-attested copies and an undertaking to produce the originals when released.
Source reference: p. 3He subsequently obtained the originals following an order of the Madhya Pradesh High Court, and the State issued a No Objection Certificate on 16 September 2026 permitting him to pursue postgraduate study, subject to completing the required rural service after the course.
Source reference: pp. 3, 7, 9The petitioner sought admission to the allotted seat under Article 226.
Source reference: p. 1Issues
1. Whether the petitioner’s failure to submit original documents by the prescribed deadline justified denying him admission, given that the documents were held by a third party under bond conditions and he had taken steps to secure their release.
Source reference: pp. 6–102. Whether the principles concerning cut-off dates and exceptional judicial relief in medical admissions precluded the requested relief.
Source reference: pp. 3–6, 10Law Applied
Article 226 of the Constitution empowers the High Court to grant appropriate relief where a public authority’s decision warrants judicial intervention.
Source reference: p. 1In Ramakrishna Medical College Hospital and Research Centre v. State of Madhya Pradesh, 2024 SCC OnLine SC 3194, the Supreme Court reiterated that a medical seat ordinarily exists only for the year in which it falls due and only until the applicable cut-off date; exceptional admission-related relief is confined to rare cases, subject to the principles discussed in S. Krishna Sradha v. State of Andhra Pradesh, (2020) 17 SCC 465.
Source reference: pp. 4–6The High Court considered these principles but distinguished Ramakrishna on its facts.
Source reference: p. 10Reasoning
The Court accepted that the petitioner could not produce the originals because they were retained under the State-imposed bond conditions, and found that he had taken steps to obtain their release before the deadline.
Source reference: pp. 7, 9The subsequent release of the documents and the State’s No Objection Certificate substantially removed the impediment and supported the petitioner’s position that the delay was not independently within his control.
Source reference: pp. 9–10In those circumstances, the Court held that he should not be denied consideration for admission solely for missing the document deadline.
Source reference: p. 10It distinguished Ramakrishna, which concerned compensatory seats in a later academic year following vacancies caused by interim judicial orders.
Source reference: p. 10Holding
The Court allowed the writ petition in terms of prayer (a), directing that the petitioner be permitted to join the MD Microbiology course at AIIMS Rishikesh against his allotted seat upon producing the requisite documents.
The judgment does not grant the separately sought refund or alternative-seat relief.
Source reference: no citationOriginal Court PDF
Anugrah VyasvsAll India Institute Of Medical Sciences , New Delhi And Ors.
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