Supreme Court Rejects Plea for Additional Medical Counselling Rounds in Uttar Pradesh

The Supreme Court of India in Neeraj Kumar Sainy & Ors. vs. State of U.P. & Ors. ruled on the validity of additional rounds of medical counselling for postgraduate medical courses in Uttar Pradesh. The case revolved around the appellants’ demand for a second, third, and mop-up round of counselling under the Uttar Pradesh Post Graduate Medical Entrance Examination (UPPGMEE) 2016 and their contention that vacant seats should not be left unfilled.

Background of the Case

The petitioners, having qualified in UPPGMEE-2016, challenged the decision of the state authorities not to conduct additional rounds of counselling beyond the first round. According to them, the Information Brochure for the entrance exam specified that three rounds of counselling should be conducted, followed by a mop-up round if seats remained vacant. However, the authorities concluded the admission process after the first round, citing a Supreme Court ruling in State of Uttar Pradesh & Ors. vs. Dinesh Singh Chauhan, which required strict adherence to the admission schedule.

They argued that this decision deprived them of their right to a fair selection process and resulted in seats remaining vacant despite meritorious candidates being available.

Key Legal Issues Considered

Whether the state was legally bound to conduct additional rounds of counselling as per the Information Brochure.
Whether the Supreme Court’s ruling in Dinesh Singh Chauhan prevented further rounds of counselling.
Whether the denial of further counselling infringed upon the rights of candidates.
Whether the maxim actus curiae neminem gravabit (an act of the court shall prejudice no one) was applicable.

Petitioner’s Arguments (Neeraj Kumar Sainy & Ors.)

The state authorities were obligated to follow the guidelines in the Information Brochure, which mandated three rounds of counselling.
The refusal to conduct further rounds led to seats remaining vacant, causing loss to students and medical institutions.
In previous years, mop-up rounds were conducted even after the official cut-off date.
The delay in admission was caused by court rulings and procedural delays beyond their control, justifying the application of the principle actus curiae neminem gravabit.

Respondents’ Arguments (State of Uttar Pradesh & Medical Council of India)

The state had already conducted the first round of counselling in compliance with the Supreme Court’s order in Dinesh Singh Chauhan.
Permitting additional rounds of counselling would violate the admission schedule mandated by the Supreme Court.
Seats remained vacant not due to administrative failure but because candidates either resigned or failed to join.
The courts have previously held that medical seats from one academic year cannot be carried forward to the next.

Supreme Court’s Observations

The Supreme Court emphasized the necessity of adhering to strict admission schedules in medical courses. It stated:

“The primary objective of structured medical admission schedules is to ensure a fair and transparent process, without creating midstream vacancies that disrupt academic sessions.”

Addressing the argument of the appellants, the Court ruled:

“Once the admission process has been completed in accordance with judicially approved regulations, subsequent petitions for additional counselling rounds disrupt the stability of medical admissions and cannot be entertained.”

The Court also rejected the argument based on the maxim actus curiae neminem gravabit, stating that:

“While judicial delays should not harm litigants, the present case does not involve an error caused by the Court. The appellants had ample opportunity to participate in the first round of counselling and cannot claim prejudice merely because additional seats remained vacant.”

Supreme Court’s Ruling

The Court dismissed the appeal and upheld the decision of the state to conclude admissions after the first round of counselling.
It ruled that further rounds of counselling would be contrary to established medical admission regulations.
The principle of actus curiae neminem gravabit was held to be inapplicable as there was no judicial error affecting the appellants.
The Court emphasized that stability in medical admissions is paramount and should not be disrupted by repeated requests for additional rounds.

Key Takeaways from the Judgment

Medical admission schedules must be strictly followed, and deviations can undermine transparency and stability.
Vacant seats cannot justify additional counselling if the admission process has concluded as per judicial orders.
The maxim actus curiae neminem gravabit applies only to judicial errors, not administrative decisions taken within legal parameters.
Candidates must participate in scheduled counselling rounds and cannot later claim entitlement to vacant seats.

Conclusion

The Supreme Court’s ruling in Neeraj Kumar Sainy & Ors. vs. State of U.P. reinforces the principle that medical admissions must adhere to structured timelines and regulatory mandates. By dismissing the appeal for additional counselling rounds, the Court has emphasized the need for stability in medical education and fairness in admission processes. The verdict sets a clear precedent that unfilled seats cannot be used to challenge completed admission procedures.

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