Supreme Court Grants MBBS Seat to Disabled Student: Landmark Judgment on Medical Education and Accessibility

The case of Om Rathod vs. The Director General of Health Services & Ors. is a landmark Supreme Court ruling on the rights of persons with disabilities in medical education. The judgment, delivered on October 25, 2024, reinstated the MBBS admission of the petitioner, a student with a locomotor disability, emphasizing the principles of reasonable accommodation, inclusion, and fair assessment of competence.

Background of the Case

Om Rathod, a meritorious student with lower limb myopathy, appeared for the NEET-UG 2024 examination under the EWS-PwD category. He secured 601 marks out of 720, ranking 84th in the All India PwD category and 4th in the State PwD category. Despite possessing a valid disability certificate, he was required to undergo another disability assessment for eligibility certification.

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The medical board at AIIMS Nagpur assessed his disability at 88% and declared him ineligible for MBBS. Rathod challenged this decision in the Bombay High Court, which upheld the AIIMS report. Aggrieved, he approached the Supreme Court, arguing that his functional competence had not been properly assessed.

Petitioner’s Arguments

• The petitioner argued that his disability had not hindered his academic achievements, and he was capable of fulfilling the functional requirements of the MBBS course.
• He contended that the AIIMS Nagpur assessment was arbitrary and lacked a functional competency test, as required by the RPWD Act.
• He pointed out that the AIIMS Delhi reassessment, ordered by the Supreme Court, also failed to follow the functional competency model, focusing instead on physical limitations.
• The petitioner emphasized that the medical profession should evaluate competence based on ability rather than disability.

Respondents’ Arguments

• The respondents maintained that the disability assessment was conducted per regulatory guidelines.
• They argued that the petitioner’s disability exceeded the permissible threshold, making him unfit for medical education.
• The AIIMS Delhi board reaffirmed that the petitioner’s disability, even with assistive devices, remained above 80%, making him ineligible.

Supreme Court’s Observations

• The Court criticized the disability assessment process, noting that it lacked a fair evaluation of the petitioner’s functional competence.
• It highlighted that the AIIMS Delhi report acknowledged the lack of clear guidelines on assessing disability with assistive devices.
• The Court observed that discrimination against persons with disabilities in professional education violates the RPWD Act and the constitutional right to equality.
• It referenced previous rulings emphasizing reasonable accommodation and substantive equality, asserting that an individual’s competence should be evaluated based on ability, not assumptions about disability.

Supreme Court’s Ruling

• The Court quashed the AIIMS Nagpur and AIIMS Delhi reports.
• It directed the creation of a supernumerary seat at AIIMS Nagpur for the petitioner.
• The Court mandated that all medical institutions must ensure compliance with accessibility norms and provide reasonable accommodation for disabled students.
• It ordered the National Medical Commission to revise guidelines to implement a functional competency model in disability assessments.

Legal Implications of the Judgment

This ruling has significant consequences for disability rights and medical education:

• Reforming Disability Assessments: The judgment mandates that disability assessments must focus on functional competence rather than arbitrary thresholds.
• Ensuring Equal Access to Medical Education: It reinforces that persons with disabilities have a right to pursue professional education with reasonable accommodations.
• Strengthening RPWD Act Compliance: The ruling ensures that institutions follow the RPWD Act’s principles of non-discrimination and equal opportunity.
• Accountability of Medical Institutions: The decision places a duty on medical colleges to create inclusive environments and remove attitudinal and structural barriers.

Conclusion

The Supreme Court’s ruling in this case is a historic victory for the rights of students with disabilities. By ensuring a fair and inclusive admissions process, the Court has reaffirmed the fundamental right to education and professional development for all. This judgment is a step toward a more equitable and accessible medical education system in India.

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Petitioner Name: Om Rathod.
Respondent Name: The Director General of Health Services & Ors..
Judgment By: Justice Dhananjaya Y Chandrachud, Justice J B Pardiwala, Justice Manoj Misra.
Place Of Incident: Nagpur, Maharashtra.
Judgment Date: 25-10-2024.

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