Featured image for Supreme Court Judgment dated 15-03-2019 in case of petitioner name Pt. Bateswari Dayal Mishr Shik vs Madhya Pradesh Nurses Registra
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Nursing College Recognition Denied: Supreme Court Upholds Regulatory Compliance

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The Supreme Court of India recently ruled on a critical case concerning the recognition of a nursing college. The case, Pt. Bateswari Dayal Mishr Shiksha Samiti vs. Madhya Pradesh Nurses Registration Council, involved a dispute over the recognition of nursing courses and compliance with statutory requirements. The Court examined whether the institution met the eligibility criteria for running B.Sc. (Nursing) and M.Sc. (Nursing) courses for the academic year 2018-19.

The judgment addressed key legal issues related to institutional compliance, mandatory approvals, and regulatory oversight in the education sector.

Background of the Case

Pt. Bateswari Dayal Mishr Shiksha Samiti, the appellant, is a registered society that operates Dayal Nursing College in Gwalior. The institution claimed that it had been running B.Sc. (Nursing) courses since 2006 and sought recognition for its newly introduced M.Sc. (Nursing) courses.

The Madhya Pradesh Nurses Registration Council (SNRC) did not grant recognition for the academic session 2018-19 due to alleged non-compliance with regulatory requirements. The appellant challenged this decision before the Madhya Pradesh High Court, which directed SNRC to conduct an inspection and decide on the recognition by 20th November 2018. However, recognition was still not granted, leading to an appeal before the Supreme Court.

Petitioner’s Arguments

The appellant, Pt. Bateswari Dayal Mishr Shiksha Samiti, argued:

  • The institution had been running the B.Sc. (Nursing) course since 2006 and had the necessary infrastructure and faculty.
  • The SNRC failed to conduct an inspection within the timeline set by the High Court, causing undue delay.
  • The inspection report found no deficiencies in faculty, laboratories, classrooms, or infrastructure.
  • The institution had received affiliation from Madhya Pradesh Medical Science University on 2nd February 2019 for its M.Sc. (Nursing) course.

Respondent’s Arguments

The Madhya Pradesh Nurses Registration Council countered:

  • The institution’s application for recognition for 2018-19 was incomplete as it lacked essential faculty details and supporting documents.
  • The institution did not have its own parent hospital, a mandatory requirement under the Indian Nursing Council guidelines.
  • The last date for submitting applications was 22nd December 2018, and the institution failed to comply with this deadline.
  • Consent for affiliation was granted only in February 2019, well after the application deadline.

Supreme Court’s Observations

The Supreme Court examined the facts and made the following key observations:

“Though the institution had been granted affiliation for running B.Sc. (Nursing) courses in previous years, there was no permission accorded for the academic session 2018-19.”

Regarding regulatory compliance, the Court noted:

“The institution’s online application form was incomplete, lacking faculty details and supporting documents. Furthermore, the institution did not have its own parent hospital, which was a mandatory requirement under the applicable regulations.”

Final Judgment

The Supreme Court ruled:

  • The appeal by Pt. Bateswari Dayal Mishr Shiksha Samiti was dismissed.
  • The High Court’s decision not to grant recognition was upheld.
  • The institution was found to be non-compliant with regulatory requirements.

The Court concluded:

“There was no occasion for granting permission to the appellant institution for running the M.Sc. (Nursing) course for the academic session 2018-19.”

Implications of the Verdict

The ruling has significant implications for the education sector:

  • Strict Enforcement of Regulations: Institutions must ensure full compliance with statutory requirements before seeking recognition.
  • Timely Application and Documentation: Delays in submission and incomplete applications can lead to rejection of recognition requests.
  • Regulatory Oversight: The judgment reinforces the role of regulatory bodies in maintaining educational standards.

The Supreme Court’s decision underscores the necessity for educational institutions to strictly adhere to legal and regulatory frameworks when seeking recognition for academic programs.


Petitioner Name: Pt. Bateswari Dayal Mishr Shiksha Samiti.
Respondent Name: Madhya Pradesh Nurses Registration Council.
Judgment By: Justice R. F. Nariman, Justice Vineet Saran.
Place Of Incident: Madhya Pradesh, India.
Judgment Date: 15-03-2019.

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Download Judgment: Pt. Bateswari Dayal vs Madhya Pradesh Nurse Supreme Court of India Judgment Dated 15-03-2019.pdf

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