Supreme Court Directs Admission Of SC‑PwBD Candidate To MBBS And Orders NMC To Revise Guidelines

A bench of Justices Vikram Nath and Sandeep Mehta heard an appeal by a Scheduled Caste person with benchmark disabilities who challenged denial of admission to the MBBS (UG) course despite securing a high category rank in NEET‑UG 2024; the appeal arose from Letters Patent Appeal No. 967 of 2024 dismissed by the Delhi High Court and the Special Leave Petition SLP (Civil) No. 29275 of 2024.

The Court allowed the appeal, set aside the High Court order and directed that the appellant be allotted a seat at AIIMS, New Delhi under the Scheduled Castes‑PwBD quota for the MBBS academic session 2025–2026 without requiring him to appear in NEET‑UG 2025. The Court found that the earlier denial of admission was "grossly illegal, arbitrary and violative" of Articles 14 and 16, observed that reasonable accommodation was a right and not charity, and directed the National Medical Commission to finalise revised guidelines in light of this Court's precedents before counselling for 2025–2026 commenced. The Court, in its reasoning, observed: "The constitutional promise of equality is not merely formal but substantive, requiring the State to take affirmative measures to ensure that PwD and PwBD can meaningfully participate in all spheres of life, including professional education. We emphasize that reasonable accommodation is not a matter of charity but a fundamental right flowing from Articles 14, 16, and 21 of our Constitution. When administrative authorities create arbitrary barriers that exclude qualified PwBD candidates, they not only violate statutory provisions but also perpetuate the historical injustice and stigmatisation. The fundamental rights and the dignity of PwD and PwBD candidates must be protected by ensuring that assessment of their capabilities is individualised, evidence‑based, and free from stereotypical assumptions that have no scientific foundation."

Background The appellant, a PwBD belonging to the Scheduled Caste category, scored 542 marks in NEET‑UG 2024 and secured a PwBD category rank of 176, above the relevant cut‑off. He suffered congenital absence of multiple fingers in both hands and involvement of toes in the left foot, with locomotor disability assessed as permanent. A Disability Certification issued by VMMC‑Safdarjung assessed disability at 68% but concluded that "the candidate is not eligible to pursue medical courses (as per NMC norms)" and that he was not eligible to avail reservation. The appellant's writ petition in the Delhi High Court was dismissed after an AIIMS three‑member board initially endorsed ineligibility; a Division Bench later directed a fresh reassessment.

Pursuant to this Court's interim directions, a five‑member Medical Board at AIIMS conducted an extensive reassessment and observed that the appellant performed skilled techniques in a simulation laboratory — chest compressions, intravenous cannulation, laryngoscope assembly, intubation and suturing — and "demonstrated functional adaptation using his existing digits during these tasks." The only minor difficulty noted related to donning standard sterilized gloves. The Supreme Court recorded that a candidate with materially lower merit had already been allotted an AIIMS seat in the same category, and held that continued exclusion of the appellant was unjustified.

The Court set aside the impugned Division Bench order, allowed the appeal and directed that the appellant be allotted a seat at AIIMS, New Delhi against the Scheduled Castes‑PwBD quota for the MBBS UG 2025–2026 academic session, without requiring fresh NEET‑UG qualification. The National Medical Commission was directed to complete revision of its guidelines in light of this Court's decisions (including Om Rathod and Anmol) within two months, and the Court emphasised the need for individualised, evidence‑based assessment and reasonable accommodation.

Case No.: 2025 INSC 623 Case Title: Kabir Paharia v. National Medical Commission & Ors. Appearances: For the Petitioner(s): Mr. Rahul Bajaj (learned counsel); Mr. Amar Jain (learned counsel); Mr. Gaurav Agarwal (Senior Counsel, pro bono) For the Respondent(s): Ms. Archana Pathak Dave, ASG (for Union of India and National Medical Commission)