Post-MD senior residency experience counts toward the mandatory three-year tenure for Super-Speciality course eligibility.

The respondent (a candidate) secured All India Rank 4 in the Super-Speciality Entrance Test for a D.M. in Critical Care Medicine at AIIMS.

AIIMS cancelled his candidature on 02.01.2026, alleging he failed to meet the eligibility criteria under Clause 4.3.2 of the Prospectus, which requires 1095 days (3 years) of requisite tenure/training by 31.01.2026.

The candidate had completed 1026 days during his MD course at GCS Medical College and argued that his 69 days of training at two previous institutes (joined and resigned during COVID-related counselling overlaps) and his 96 days as a Senior Resident post-MD should be counted.

A Single Judge quashed the cancellation, leading to this intra-court appeal by AIIMS.

Whether the 1095-day training tenure required under Clause 4.3.2 of the Prospectus must be completed in a single institute or can be aggregated from multiple institutes where the candidate did not complete the degree.

Whether experience gained as a Senior Resident post-award of the MD degree can be counted toward the 1095-day eligibility requirement.

The Court applied the principle of judicial restraint in academic matters, holding that Courts should not substitute their own interpretation for that of experts unless there is arbitrariness or violation of statutory rules.

This principle was seen in *Sanchit Bansal v. Joint Admission Board*.

It also applied Clause 2.1 of the *Post-Graduate Medical Education Regulations, 2023 (PGMER)*, which prescribes a 3-year duration for PG courses.

Crucially, the Court relied on the precedent set in *Dr. Deepak Suresh Kumar v. AIIMS* (2024), where the court recognized that post-MD training could be counted to bridge deficiency in tenure if previously permitted by the institute.

The Court agreed with AIIMS that eligibility criteria fall within the domain of academic policy and that "tenure" generally refers to the training leading to the degree; thus, the 69 days spent at institutes the respondent resigned from could not be counted as they were irrelevant to his MD degree.

However, the Court noted that the respondent had disclosed 96 days of experience as a Senior Resident post-MD in his application.

Following the logic in *Dr. Deepak Suresh Kumar*, where AIIMS itself had allowed a candidate (Dr. Jay Mehta) to complete deficient training post-degree, the Court held that it would be inconsistent and inequitable to deny the respondent the benefit of his 96-day post-MD residency.

Adding 1026 days (MD tenure) and 96 days (Senior Residency) totaled 1122 days, exceeding the 1095-day requirement.

The Court dismissed the appeal and directed AIIMS to allow the respondent to complete admission formalities for the D.M. (CCM) programme immediately, as it was the final day for admissions.

The cancellation order dated 02.01.2026 remains quashed.