Medical College Fee Regulation: Supreme Court Orders Fee Fixation Committee Oversight

The case of M. Aamira Fathima & Others v. Annamalai University & Others is a landmark ruling by the Supreme Court regarding the regulation of tuition fees in medical and engineering institutions. The Court ruled that universities cannot independently fix fees for professional courses and must comply with the fee determination by the statutorily mandated Committee on Fixation of Fee under the Tamil Nadu Educational Institutions (Prohibition of Collection of Capitation Fee) Act, 1992 (1992 Act).

Background of the Case

The petitioners were students who had taken admission in the Rajah Muthiah Medical College, which was established by Annamalai University. They challenged the exorbitant tuition fees charged by the university, arguing that the fees exceeded those fixed by the government and the Fee Fixation Committee for other private medical institutions.

The university had set the tuition fees at Rs. 5.54 lakhs per annum for MBBS students. In contrast, the Fee Fixation Committee had approved Rs. 2.30 to 2.80 lakhs for private colleges and Rs. 12,290 for government medical colleges.

The students filed a writ petition in the Madras High Court seeking the intervention of the Fee Fixation Committee to regulate their tuition fees. The Single Judge dismissed the petition, holding that the students were bound by the fee structure mentioned in the prospectus at the time of admission. The Division Bench upheld this decision, leading the students to appeal to the Supreme Court.

Arguments by the Parties

Petitioners’ Arguments

• The university’s fee structure violated the provisions of the 1992 Act, which mandates that professional course fees be fixed by the Committee on Fixation of Fee.
• The university could not charge fees higher than those approved by the committee.
• The 2013 Annamalai University Act does not override the regulatory provisions of the 1992 Act.
• The Fee Fixation Committee was a statutory body established following the Supreme Court’s ruling in Islamic Academy of Education v. State of Karnataka (2003) and must oversee fee determination.
• The decision of the High Court was erroneous in ruling that students had no right to challenge the fees after accepting admission.

Respondents’ Arguments

• The university argued that it had autonomy under the 2013 Annamalai University Act to determine its fees.
• They contended that the Fee Fixation Committee’s oversight was applicable only to private colleges and not to a university established under a State Act.
• The university was running at a financial deficit and required higher fees to maintain its standards.
• The students voluntarily took admission after agreeing to the prescribed fee and could not challenge it later.

Supreme Court’s Observations

The Supreme Court examined the 1992 Act and its amendments following the Islamic Academy ruling and held:

• The Fee Fixation Committee applies to all educational institutions imparting professional education, including universities.
• The university’s financial deficit does not justify ignoring statutory regulations on fee fixation.
• Students cannot be estopped from challenging illegal fee structures, as statutory protections override contractual agreements.
• The 2013 Annamalai University Act does not provide an exemption from the regulatory framework of the 1992 Act.
• The High Court’s ruling was incorrect in dismissing the students’ plea.

Final Judgment

The Supreme Court allowed the appeal and set aside the judgments of the Madras High Court. The Court directed:

• The university must submit all financial records and fee details to the Fee Fixation Committee within two weeks.
• The committee must determine a reasonable fee for MBBS and BDS courses for the academic years 2013-14 onward.
• If the fees were found excessive, the university must refund the excess amount to students.
• The entire process must be completed by August 31, 2018.

This ruling reinforces the principle that universities cannot arbitrarily determine fees for professional courses and must comply with government-mandated regulations.

Petitioner Name: M. Aamira Fathima & Others.
Respondent Name: Annamalai University & Others.
Judgment By: Justice Uday Umesh Lalit, Justice Arun Mishra.
Place Of Incident: Tamil Nadu.
Judgment Date: 13-07-2018.

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