Madhya Pradesh High Court
Education LawConstitutional Law

Previously registered NEET candidates cannot switch to NRI quota during mop-up counselling, MP High Court rules

Yamya Gole vs State Of M.P.

Madhya Pradesh High CourtJUDGMENT: October 07, 20263 MIN READSOURCE JUDGMENT
Previously registered NEET candidates cannot switch to NRI quota during mop-up counselling, MP High Court rules. Yamya Gole vs State Of M.P.. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, who had registered for and participated in earlier rounds of State medical counselling, sought to change their category to the NRI quota for the Mop-Up round.

Source reference: para. 2–4

The portal did not permit previously registered candidates to edit their profiles, although fresh candidates could register and select a category.

Source reference: para. 2–4

They challenged Rules 6(ख), 6(ग), 12(2), 13 and 14 of the Madhya Pradesh Medical Education Admission Rules, 2018, as amended up to 2 July 2024, and sought an edit window and verification of their NRI eligibility documents.

Source reference: para. 5–6

The State opposed relief on the basis of the rules, the counselling timetable and the need to preserve the finalized merit list and ongoing choice-filling process.

Source reference: para. 17–22
02

Issues

Whether the rules and portal arrangements, which permitted fresh candidates to register but barred previously registered candidates from changing their category during the Mop-Up round, violated Article 14 of the Constitution.

Source reference: para. 10, 24

Whether Rules 13 and 14, providing for the conversion of unfilled NRI seats to the unreserved pool, were arbitrary or unconstitutional.

Source reference: para. 12, 20, 27

Whether the Court could direct the authorities to reopen the portal and permit the petitioners to change their category after registration had closed and the merit list had been published.

Source reference: para. 22, 25, 31
03

Law Applied

The Court considered Rules 6(ख), 6(ग) and 12(2) of the Madhya Pradesh Medical Education Admission Rules, 2018 as governing registration and the finality of candidates’ category choices, and Rules 13 and 14 as providing for the conversion of unfilled NRI seats to the unreserved pool.

Source reference: para. 24, 27, 32

It also applied Articles 14, 19(1)(g) and 21 of the Constitution, holding that counselling procedures and reasonable restrictions may regulate a candidate’s participation.

Source reference: para. 24, 30

Regulation 4.3 of the Graduate Medical Education Regulations, 2023 requires common counselling based on merit and compliance with published guidelines and timelines; Regulation 4.5 prohibits admissions outside that prescribed process.

Source reference: para. 28

The Court relied on P.A. Inamdar v. State of Maharashtra, (2005) 6 SCC 537, concerning professional education seats; Ashish Ranjan, M.A. No. 500 of 2026 in W.P. (Civil) No. 76 of 2015, order dated 23 March 2026, concerning adherence to cutoff dates; and National Medical Commission v. Vedantaa Institute of Medical Science & Ors., SLP (C) No. 12177 of 2026, order dated 6 April 2026, concerning interim directions that bypass the admission schedule.

Source reference: para. 15, 27, 29
04

Reasoning

The Court treated candidates who had registered in earlier rounds and candidates entering afresh in the Mop-Up round as distinct classes, finding that freezing earlier profiles served the administrative purpose of avoiding repeated verification.

Source reference: para. 24

By the time relief was considered, registration had closed, the merit list had been published and choice filling had begun; reopening the portal would require fresh verification and alteration of the ongoing process, contrary to the prescribed timetable.

Source reference: para. 25, 31

The Court also noted that 268 eligible NRI candidates were competing for 175 physical MBBS NRI vacancies, and concluded that admitting the petitioners at that stage would prejudice candidates who had followed the schedule.

Source reference: para. 26

It held that conversion of unfilled NRI seats to the general pool did not waste seats, but enabled their allocation to other meritorious candidates under the published rules.

Source reference: para. 27

Prior interim orders did not displace the statutory schedule or establish an entitlement to equivalent relief at this final stage.

Source reference: para. 29
05

Holding

The Court held that the impugned rules were legally sustainable and that the authorities’ actions did not establish arbitrariness, jurisdictional error or a violation of the petitioners’ constitutional rights.

It rejected the challenge to the rules and dismissed all three writ petitions as lacking merit, with no order as to costs.

Source reference: para. 33
Madhya Pradesh High Court

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Yamya GolevsState Of M.P.

Madhya Pradesh High Court · October 07, 2026

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