Madras High Court

Students admitted prior to government takeover constitute a distinct class ineligible for prospective fee reductions.

S.KOKITH vs THE PRINCIPAL SECRETARY TO GOVERNMENT

Madras High CourtJUDGMENT: March 26, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners are MBBS students admitted to Rajah Muthiah Medical College & Hospital (RMMC), Chidambaram, between the academic years 2018–2021

Source reference: para. 1

RMMC was originally a private institution under Annamalai University, a private university established by a 1928 Statute

Source reference: para. 3

In 2013, the State took over Annamalai University via the Annamalai University Act, 2013, making it a State University, though RMMC continued to operate on a self-financing basis

Source reference: para. 3, 5

Following litigation and a Supreme Court directive, a Fee Fixation Committee fixed RMMC's fees significantly higher than government colleges (approx. ₹5.44 lakhs), which the Supreme Court later capped at ₹4,00,000/- (par with private unaided colleges) as an interim measure

Source reference: para. 5-6

On 27.01.2021, the government formally took over RMMC, renaming it 'Government Medical College, Cuddalore,' and subsequently issued G.O.Ms.No. 45 (01.02.2021) fixing the annual fee at ₹13,610/-

Source reference: para. 7

The petitioners challenged G.O.Ms.No. 204 (26.10.2021), which clarified that the reduced fee applied only prospectively to students admitted from 2021-2022 onwards, while petitioners (admitted earlier) remained liable for ₹4,00,000/- per annum

Source reference: para. 9-11
02

Issues

1. Whether G.O.Ms.No. 45, which fixed the government fee structure, applies to students admitted to RMMC prior to its formal transition to a Government Medical College affiliated with Dr. MGR Medical University

Source reference: para. 11

2. Whether the classification of students based on their year of admission (pre-takeover vs. post-takeover) is arbitrary, discriminatory, or violative of Article 14 of the Constitution

Source reference: para. 12, 14
03

Law Applied

The court applied the principle of prospective application of administrative orders and the doctrine of reasonable classification under Article 14 of the Constitution

Source reference: para. 24-25

It relied on the Annamalai University (Second Amendment) Act, 2013 regarding the university's status and the Dr. MGR Medical University Act regarding affiliation changes

Source reference: para. 19

The court further referenced the Supreme Court’s holding in Aamira Fathima v. Annamalai University (2018) regarding the distinction between self-financing and government institutions

Source reference: para. 11

The court further referenced the prospective nature of college affiliations

Source reference: para. 20
04

Reasoning

The court reasoned that a fundamental shift occurred in the college’s status and affiliation starting from the 2021-2022 academic year.

Source reference: para. 17, 19

Students admitted prior to 2021-2022, like the petitioners, joined RMMC when it was affiliated with Annamalai University and accepted the terms of the prospectus, which prescribed a fee of ₹4,00,000/-

Source reference: para. 17, 23

The court noted that these students will continue to be governed by Annamalai University regulations and will receive their degrees from that university

Source reference: para. 17, 19

Conversely, students admitted from 2021-2022 onwards are admitted to the renamed 'Government Medical College, Cuddalore,' which is affiliated with Dr. MGR Medical University

Source reference: para. 19

The court found that G.O.Ms.No. 45 and G.O.Ms.No. 122 explicitly intended for the new fee structure to be prospective

Source reference: para. 22-23

Furthermore, the court rejected the plea of parity with Perundurai Medical College, noting that the latter had always been affiliated with Dr. MGR Medical University and was under a different administrative history

Source reference: para. 15

Thus, the court held that the two sets of students constitute distinct classes, and the classification is based on an "intelligible differentia" related to the timing of the government's total administrative and financial takeover

Source reference: para. 24-25
05

Holding

The court dismissed the batch of writ petitions, upholding the validity of G.O.Ms.No. 204

It held that the petitioners are not entitled to the reduced fee of ₹13,610/- and must pay the fee of ₹4,00,000/- as per their original admission terms

Source reference: para. 24

The court concluded that there was no arbitrariness or unfair discrimination because the transition of the institution into a full-fledged government college was prospective and tied to a change in university affiliation

Source reference: para. 25

All connected miscellaneous petitions were closed, and no costs were awarded

Source reference: para. 25
Madras High Court

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S.KOKITHvsTHE PRINCIPAL SECRETARY TO GOVERNMENT

Madras High Court · March 26, 2026

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