Featured image for Supreme Court Judgment dated 08-10-2020 in case of petitioner name Ankita Kailash Khandelwal & Or vs State of Maharashtra & Ors.
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Medical Students’ Suspension Overturned: Supreme Court Rules on Rights and Fair Trial

The case of Ankita Kailash Khandelwal & Ors. vs. State of Maharashtra & Ors. is a crucial Supreme Court ruling that addresses issues of fair trial, procedural fairness, and the fundamental rights of medical students accused of abetment to suicide and ragging under multiple legal provisions, including the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, and the Maharashtra Prohibition of Ragging Act, 1999.

The Court ruled that the suspension of the accused medical students was improper and that they should be allowed to continue their medical education while facing trial. The judgment emphasizes the balance between the rights of accused individuals and the interests of justice.

Background of the Case

The appellants, Dr. Ankita Kailash Khandelwal, Dr. Hema Suresh Ahuja, and Dr. Bhakti Arvind Mehare, were postgraduate students at Topiwala National Medical College, Mumbai, pursuing their MD in Gynecology and Obstetrics. They were accused of harassing their junior colleague, Dr. Payal Tadvi, who subsequently died by suicide on 22 May 2019.

The incident led to an FIR under the following laws:

  • Section 306 IPC – Abetment of suicide
  • Section 34 IPC – Common intention
  • Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989
  • Maharashtra Prohibition of Ragging Act, 1999

The three doctors were arrested on 29 May 2019 and later released on bail by the Bombay High Court on 9 August 2019, with stringent conditions, including the suspension of their medical licenses and a prohibition on entering the college premises.

Petitioners’ (Accused Doctors) Arguments

The petitioners, through their counsel Siddharth Luthra, argued that:

  • There was no direct evidence linking them to the alleged harassment leading to suicide.
  • Their academic future was at stake as they had already completed two years of their three-year MD program.
  • The conditions imposed by the High Court, including the suspension of their licenses and prohibition from entering the college, were excessive and violated their Article 21 rights to life and liberty.
  • Since the statements of key witnesses had already been recorded under Section 164 CrPC, there was no risk of influencing them.
  • They sought relaxation of conditions so they could continue their education at another medical institution.

Respondents’ (State of Maharashtra & Others) Arguments

The respondents, including the complainant’s family, opposed the relaxation, arguing that:

  • The accused had created a hostile environment that led to the victim’s suicide.
  • Allowing them to return to their medical education would undermine the gravity of the allegations.
  • The presence of the accused in the college could intimidate witnesses.
  • The Medical Council of India’s regulations prohibited migration or transfer of students in postgraduate medical courses.

Supreme Court’s Observations and Judgment

The Supreme Court, in a bench led by Uday Umesh Lalit, with Vineet Saran and Ajay Rastogi, made the following key observations:

  • Right to Education: The Court emphasized that even an accused individual has the right to continue education unless proven guilty.
  • Arbitrary Suspension: The Court found that the order suspending the students from their studies was not legally justified and was based solely on the FIR.
  • Prevention of Witness Tampering: Since witness statements had already been recorded under Section 164 CrPC, concerns about tampering were unfounded.
  • Medical Education Regulations: The Court noted that the Medical Council of India’s regulations prohibited student migration but ruled that the accused could continue their studies at their original institution.

Final Judgment

The Supreme Court ruled:

  • The accused doctors would be allowed to return to their medical college to complete their postgraduate studies.
  • Their medical licenses would be reinstated.
  • They must not attempt to influence any witnesses.
  • They must attend all court proceedings unless specifically exempted.
  • They should avail of study leave to minimize their presence at the institution.

Conclusion

The Supreme Court’s ruling underscores the importance of procedural fairness and the right to education for accused individuals. While recognizing the gravity of the allegations, the Court ensured that legal safeguards were in place to prevent miscarriage of justice. The judgment strikes a balance between protecting the rights of the accused and ensuring a fair trial.


Petitioner Name: Ankita Kailash Khandelwal & Ors..
Respondent Name: State of Maharashtra & Ors..
Judgment By: Justice Uday Umesh Lalit, Justice Vineet Saran, Justice Ajay Rastogi.
Place Of Incident: Mumbai, Maharashtra.
Judgment Date: 08-10-2020.

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