Kyrgyzstan-Trained Doctor To Serve One-Year Internship, As Odisha HC Finds 2021 CRMI Rules Inapplicable To Her Pre-2021 Course

The petitioner enrolled in a six-year M.D. (General Medicine) course in Kyrgyzstan in 2017.

Because of the COVID-19 pandemic, she was in India from 22 July 2020 to 13 November 2021, and the institute certified that she later compensated for missed online classes by attending physical classes for 9 months and 10 days.

After passing the screening test and obtaining provisional registration, she was directed by the Odisha Council of Medical Registration to complete two years of internship: one year of Clerkship and one year of CRMI.

She challenged that direction, contending that the CRMI Regulations, 2021 did not apply because she had begun her foreign medical education before those Regulations came into force.

The Council also relied on a calculated shortfall in her compensated attendance to justify the additional year.

Regulation 5(1)(b) of the CRMI Regulations, 2021 excludes from the Regulations candidates who were pursuing education in foreign institutions before the Regulations came into force.

Schedule II, paragraph 2(a) provides that foreign medical graduates regulated by the National Medical Commission (Foreign Medical Graduate Licentiate) Regulations, 2021 must undergo internship at par with Indian medical graduates if they seek permanent registration.

The Court also considered the Odisha Council’s proposal, approved by the National Medical Commission’s UGMEB, to condone specified shortfalls of up to 30 days in compensated physical attendance; the respondents relied on this framework to distinguish the petitioner’s alleged shortfall from those of other doctors.

No judicial precedent was relied upon in the Court’s reasoning.

The Court found that the petitioner began her course in 2017, before the CRMI Regulations, 2021 came into force. Regulation 5(1)(b) therefore made those Regulations inapplicable to her, and the additional one-year CRMI requirement could not be imposed under them.

The Court also accepted the institute’s certificate that she had compensated for the period of missed online classes through physical attendance.

In that context, it rejected the respondents’ calculation of a shortfall and held that the certified compensation could not be disputed after the petitioner had been permitted to sit the screening test and had received provisional registration.

It further observed that a shortfall exceeding 30 days had been condoned for another doctor and considered the petitioner entitled to similar treatment.

It interfered with the order dated 17 January 2026 to that extent and directed the respondents to allow the petitioner to complete one year of internship instead of two.

The writ petition was disposed of accordingly.