Medical College Recognition and Bed Occupancy: Supreme Court Orders Fresh Inspection

The case of Subharti Medical College vs. Union of India & Others revolves around the denial of recognition for increased MBBS seats due to alleged deficiencies in hospital facilities, particularly bed occupancy. The Supreme Court was tasked with determining whether the Ministry of Health and Family Welfare and the Medical Council of India (MCI) had acted fairly in denying the college’s application.

Background of the Case

Subharti Medical College applied to the Ministry of Health and Family Welfare to increase its MBBS seats from 100 to 150. The MCI conducted an assessment on March 27, 2017, and cited deficiencies in its report, including:

• Bed occupancy of only 55.27% at 10:00 AM on the day of assessment.
• Shortage of residents (5.81%).
• Inflated data on clinical material and casualty attendance.
• Deficiencies in ward visibility and availability of sterilized treatment trays.

Arguments Presented

Petitioners’ Arguments (Subharti Medical College):

• The assessment report’s finding of low bed occupancy was unreliable and did not reflect the actual patient load.
• The Hearing Committee had concluded that there were no faculty or resident deficiencies.
• The Ministry’s decision to debar the college for two years was excessive and unfair.

Respondents’ Arguments (Union of India & MCI):

• The MCI’s inspection was conducted according to standard procedures and found substantial deficiencies.
• Bed occupancy was a critical factor in determining a medical college’s eligibility for increased seats.
• The college had failed to conclusively prove that it met the necessary standards.

Supreme Court’s Ruling

A bench comprising Chief Justice Dipak Misra, Justice A.M. Khanwilkar, and Justice D.Y. Chandrachud ruled that the denial of increased seats lacked conclusive findings. The key points from the judgment were:

• The MCI’s findings on bed occupancy were inconclusive and required fresh verification.
• The Ministry’s decision to debar the college for two years was excessive and not based on definitive evidence.
• The Court directed a fresh inspection within three months to verify bed occupancy and other deficiencies.
• The college’s bank guarantee of Rs. 2 crore should not be encashed but kept valid until a final decision was reached.

Important Extract from the Judgment:

“The Hearing Committee is of the view that the bed occupancy as claimed by the college cannot be validated by this Committee and requires physical verification.”

Conclusion

This ruling highlights the importance of due process in medical college assessments. While ensuring compliance with medical education standards is crucial, institutions must be given a fair opportunity to rectify deficiencies before facing punitive actions.

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Download Judgment: Subharti Medical Col vs Union of India & Oth Supreme Court of India Judgment Dated 08-09-2017.pdf