Facts
The petitioner, an OBC candidate and person with benchmark disability, secured NEET-UG 2025 All India Rank 70,0126, OBC category rank 31,652 and disability rank 1,443. He was allotted Darbhanga Medical College and Hospital, Laheriasarai, through UGMAC-2025.
Source reference: para. 2Under the Board’s prospectus, candidates claiming disability-quota benefits were required to obtain certification from an empanelled institution; for locomotor, visual, hearing, speech and language disabilities, examination by IGIMS was prescribed.
Source reference: para. 3The petitioner was examined by IGIMS and a disability certificate was issued on 13 November 2025.
Source reference: para. 4His provisional admission was initially accepted, subject to verification, but was subsequently cancelled by Memo No. 8253 dated 25 November 2025 and the committee’s order dated 17 December 2025.
Source reference: paras. 5–7The committee objected that the submitted reports were not from institutions appearing on the relevant BCECE/NMC/MCC lists and that the certificate contained an incorrect institutional reference.
Source reference: paras. 5–7KGMU, Lucknow, thereafter verified that the certificate had genuinely been issued by it and clarified that the erroneous mention of Dr. B.K. Ojha resulted from a software/portal error.
Source reference: para. 8IGIMS also acknowledged that the petitioner’s assessment had been affected by the non-availability of requisite software.
Source reference: paras. 16, 19The petitioner challenged the cancellation before the High Court. The Board informed the Court that three disability-category seats remained vacant.
Source reference: para. 15Issues
1. Whether the petitioner’s provisional admission could be cancelled on account of discrepancies in his disability certificate and assessment attributable to software or technical deficiencies of the concerned institutions, when the issuing institution had subsequently verified the certificate as genuine.
Source reference: paras. 17–242. Whether the Court could direct the respondents to restore/admit the petitioner against a vacant disability-category seat and protect his academic progression despite his having missed classes because of the cancellation.
Source reference: paras. 27, 29–343. Whether the writ petition was liable to be rejected on the ground of delay or laches.
Source reference: para. 28Law Applied
The Court applied the requirements of the UGMAC-2025 prospectus and the applicable NMC/MCC framework concerning disability certification and examination by designated institutions.
Source reference: paras. 3, 7, 14It applied the principle that a candidate cannot be made to suffer for an administrative, infrastructural or software-related defect attributable to the authorities.
Source reference: no citationThe Court relied on the maxim commodum ex injuria sua nemo habere debet—no person may take advantage of his own wrong—and on Kusheshwar Prasad Singh v. State of Bihar & Ors., (2007) 11 SCC 447, which holds that a wrongdoer cannot profit from a wrong or prevent the performance of an obligation and then rely on that non-performance.
Source reference: para. 25It further relied on S. Krishna Sradha v. State of Andhra Pradesh & Ors., (2020) 17 SCC 465, concerning protection of a student’s academic career where denial of admission was not attributable to the candidate.
Source reference: para. 29Reasoning
The Court found that the petitioner had complied with the prescribed procedure by presenting himself for assessment before IGIMS and that the discrepancy in the certificate was caused by a portal/software error, not by any fault or misrepresentation on his part.
Source reference: paras. 18–20KGMU, the notified institution that issued the certificate, expressly confirmed its genuineness and explained the incorrect institutional entry.
Source reference: para. 21Further, IGIMS admitted that the required software for assessing functional competency was unavailable, making the technical deficiency attributable to the institution rather than the petitioner.
Source reference: paras. 19, 23Once the issuing institution had verified the certificate, and no contrary medical finding had been shown, cancellation solely on the basis of the technical discrepancy was held arbitrary and unsustainable.
Source reference: paras. 21–24The Court also considered the availability of three vacant disability-category seats and held that the petitioner had approached the Court without undue delay.
Source reference: paras. 27–28Applying the rule against permitting authorities to benefit from their own administrative deficiencies, and the principle of safeguarding an academic career where the candidate was not at fault, the Court granted restorative relief.
Source reference: paras. 25–30Holding
The High Court allowed the writ petition and set aside Memo No. 8253 dated 25 November 2025 and the committee’s order dated 17 December 2025 cancelling the petitioner’s provisional admission.
The respondents were directed to admit the petitioner against an appropriate disability-category seat for the 2025–26 academic session, subject to completion of formalities and payment of prescribed fees, preferably within two weeks.
Source reference: para. 32Since the petitioner had been prevented from attending classes by the unsustainable cancellation, the respondents were directed to permit him to join the next available batch and make suitable academic arrangements to prevent further loss of his academic year.
Source reference: para. 33He was also permitted to complete academic requirements and examinations in a manner protecting his academic progression, without receiving any undue advantage over similarly situated students.
Source reference: para. 34Original Court PDF
Siddharth RajvsThe State of Bihar
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