Procedural Rigidity Cannot Defeat Substantive Justice Where Systemic Failures Prevent Production of Original Documents

In brief

The question

1. Whether the High Court of Delhi has territorial jurisdiction to entertain the petition given that the allotted college and the current college are located outside Delhi

The court held

The court held that it possessed territorial jurisdiction as the seat allocation authority sits in Delhi

It also directed

It ruled that a meritorious candidate cannot be penalized for systemic deficiencies

The petition was allowed; the court directed Respondent No. 5 (RDMC) to release the Petitioner's original documents within one week

Respondents No. 1 and 2 were directed to accept the documents and, if found in order, grant the Petitioner admission to the MD (Pharmacology) course at AIIMS Bhubaneswar

01Facts

The Petitioner, a medical professional, secured a seat in MD (Physiology) at Rani Durgavati Medical College (RDMC/Respondent No. 5) via NEET-PG 2025 and deposited his original documents on 07.02.2026

p. 3

Subsequently, on 21.02.2026, he was allotted a preferred seat in MD (Pharmacology) at AIIMS Bhubaneswar (Respondent No. 2) through the INI-CET January 2026 Open Round

p. 3

Upon attempting to resign from RDMC to join AIIMS, RDMC informed him that no "resignation" provision existed and refused to return his original documents

p. 4

Consequently, AIIMS Bhubaneswar denied the Petitioner admission on 26.02.2026 because he could not produce the original certificates by the 28.02.2026 deadline, despite his submission of scanned copies and an undertaking

p. 4

The Petitioner challenged this denial and the forfeiture of his Rs. 3,00,000/- security deposit

p. 2

02Issues

i.1. Whether the High Court of Delhi has territorial jurisdiction to entertain the petition given that the allotted college and the current college are located outside Delhi

pp. 8 / para. 18-20

ii.2. Whether a meritorious candidate can be denied admission due to a "systemic failure" and the inability to produce original documents withheld by another institution

p. 11 / para. 27 · p. 25 / para. 46

03Law Applied

The court applied Article 226(2) of the Constitution of India, which allows a High Court to exercise jurisdiction if the cause of action arises "wholly or in part" within its territories

p. 10

It relied on Union of India v. Adani Exports Ltd. to define 'cause of action' as a bundle of facts having a nexus to the lis

p. 12

The doctrine of forum conveniens from Sterling Agro Industries Ltd. v. Union of India was applied to determine the appropriateness of the forum

p. 14

On the merits, the court invoked Asha v. Pt. B.D. Sharma University of Health Sciences, establishing that a meritorious student should not suffer for circumstances beyond their control

p. 6

Finally, the court interpreted the INI-CET Prospectus clauses, which vested sole authority for seat allocation and dispute resolution in AIIMS New Delhi and the Delhi Courts

pp. 16-17, 19

Provisions in the judgment · 4

All-India Institute of Medical Sciences Act, 1956 ...

National Institute Of Mental Health And Neuro-Sciences, Bangalore Act, 2012 ...

National Medical Commission Act, 2019 ...

Right of Children to Free and Compulsory Education Act, 2009 ...

04Reasoning

On jurisdiction, the court found that although the colleges were in Odisha and Uttar Pradesh, Respondent No. 1 (AIIMS New Delhi)—the nodal agency responsible for the conduct of exams and "Seat Allocation"—is situated in Delhi

p. 18 · ¶ 34

Furthermore, the Prospectus specifically included an exclusive jurisdiction clause for Delhi regarding seat allocation disputes

pp. 19-20

On the merits, the court reasoned that the Petitioner’s failure to produce documents was not due to negligence but an "administrative vacuum" and "systemic failure" because RDMC provided no mechanism for resignation

pp. 24-25

The court noted that the Petitioner demonstrated bona fides by reporting to AIIMS Bhubaneswar before the deadline with scanned documents

p. 24

It held that procedural rigidity in the prospectus regarding physical verification must yield to substantive justice, as the primary purpose of verification (authenticity) was satisfied by the scans and RDMC’s confirmation of custody

p. 26 · ¶ 49

05Holding

The court held that it possessed territorial jurisdiction as the seat allocation authority sits in Delhi

p. 18

It ruled that a meritorious candidate cannot be penalized for systemic deficiencies

p. 25

The petition was allowed; the court directed Respondent No. 5 (RDMC) to release the Petitioner's original documents within one week

p. 27

Respondents No. 1 and 2 were directed to accept the documents and, if found in order, grant the Petitioner admission to the MD (Pharmacology) course at AIIMS Bhubaneswar

p. 27

LawLens.Delhi High Court

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