Supreme Court Upholds Revocation of Essentiality Certificate for Medical College in Madhya Pradesh

The Supreme Court of India recently ruled in the case of Sukh Sagar Medical College & Hospital vs. State of Madhya Pradesh & Ors., upholding the state government’s decision to revoke the Essentiality Certificate granted to the appellant-trust for establishing a medical college. The ruling emphasized that medical institutions failing to meet the required standards cannot continue operations and that the state has the authority to revoke an Essentiality Certificate when justified.

The case revolved around the Madhya Pradesh government’s decision to withdraw the Essentiality Certificate granted to the appellant-trust for setting up Sukh Sagar Medical College & Hospital in Jabalpur. The state’s decision was based on repeated failures to rectify deficiencies in infrastructure and faculty, as pointed out by the Medical Council of India (MCI). The Supreme Court, after analyzing the legal framework and precedents, dismissed the appeal and affirmed the state’s right to act in the larger public interest.

Background of the Case

The appellant-trust had applied for an Essentiality Certificate from the Government of Madhya Pradesh to establish a medical college with an intake capacity of 150 students. The certificate was issued on August 27, 2014, with the condition that the college would meet the Medical Council of India (MCI) norms before admitting students.

The trust subsequently sought approval from the Medical Council of India (MCI) and the Ministry of Health and Family Welfare to start the college. However, upon inspection, the MCI found significant deficiencies, including fake records of patients, inadequate faculty, poor hospital infrastructure, and lack of required clinical material. Despite being given multiple opportunities to rectify these deficiencies, the appellant-trust failed to meet the standards.

As a result, the Central Government refused to renew the college’s approval for the academic years 2017-18, 2018-19, and 2019-20. Given the continued non-compliance, the Government of Madhya Pradesh issued a show-cause notice in August 2019, proposing to revoke the Essentiality Certificate. After reviewing the response, the state authorities formally revoked the certificate on September 5, 2019.

Arguments of the Petitioner

The appellant-trust challenged the revocation of the Essentiality Certificate on the following grounds:

• The state government had no authority to revoke an Essentiality Certificate once issued.
• The deficiencies pointed out by the MCI were minor and could have been rectified with additional time.
• The revocation of the certificate was contrary to the Supreme Court’s decision in Chintpurni Medical College & Hospital vs. State of Punjab, which held that a state government cannot withdraw an Essentiality Certificate once granted.
• The college had made substantial investments in infrastructure and hospital facilities, which should be taken into account before such an extreme decision was made.

Arguments of the Respondent

The State of Madhya Pradesh defended the revocation on the following grounds:

• The trust had failed to rectify the deficiencies noted by the MCI despite repeated opportunities.
• The Essentiality Certificate was granted based on the trust’s assurance that it would meet the required medical education standards, which it failed to do.
• The state was acting in the best interest of students who were left in limbo due to the non-functioning medical college.
• The Supreme Court’s ruling in Chintpurni Medical College did not apply to cases where a college had completely failed to meet the minimum educational requirements.

Supreme Court’s Key Findings

1. Authority of the State to Revoke an Essentiality Certificate

The Supreme Court held that while an Essentiality Certificate is a prerequisite for establishing a medical college, it does not guarantee indefinite validity. The Court ruled:

“A state government has the authority to revoke an Essentiality Certificate where it is found that the substratum on which the certificate was issued has disappeared.”

2. Failure to Meet Minimum Educational Standards

The Court emphasized that Sukh Sagar Medical College & Hospital had repeatedly failed to meet the minimum infrastructure and faculty requirements necessary to train medical professionals. It observed:

“When a college is unable to rectify fundamental deficiencies over multiple academic years, the state has an obligation to act in the public interest and withdraw permissions that allow it to operate.”

3. Non-Applicability of the Chintpurni Medical College Case

The appellant-trust relied heavily on the Supreme Court’s decision in Chintpurni Medical College, which held that a state cannot withdraw an Essentiality Certificate once granted. However, the Court distinguished the two cases:

“Unlike in Chintpurni, where the state government arbitrarily withdrew the certificate, in the present case, the college has continuously failed to meet basic operational standards, leading to severe consequences for students.”

4. Protection of Student Interests

The Court also noted that the withdrawal of the certificate was necessary to protect students. It highlighted that:

“It is the duty of the state to ensure that students are not admitted to a medical college that lacks basic infrastructure, faculty, and hospital facilities necessary for medical training.”

Final Judgment

After carefully examining the case, the Supreme Court:

• Upheld the revocation of the Essentiality Certificate by the Government of Madhya Pradesh.
• Reiterated that a state government has the authority to revoke an Essentiality Certificate when justified.
• Dismissed the appeal filed by Sukh Sagar Medical College & Hospital.
• Directed the college to remove all deficiencies and apply afresh if it wished to re-establish its eligibility.

Key Takeaways from the Judgment

• States have the authority to revoke an Essentiality Certificate when a medical college fails to meet operational standards.
• Medical colleges must adhere to the conditions set forth in their initial approval and rectify deficiencies within a reasonable time.
• The Supreme Court’s ruling in Chintpurni Medical College does not apply when a college’s inability to function affects students and public health.
• Student welfare and public health are primary concerns when determining the viability of a medical college.

Conclusion

The Supreme Court’s decision in this case reaffirms the state government’s power to regulate medical education and ensure that only institutions meeting prescribed standards are allowed to operate. This ruling will serve as a precedent for similar cases where medical colleges fail to fulfill their commitments, thereby safeguarding the interests of students and the medical profession.

Petitioner Name: Sukh Sagar Medical College & Hospital.
Respondent Name: State of Madhya Pradesh & Ors..
Judgment By: Justice A.M. Khanwilkar, Justice Dinesh Maheshwari, Justice Sanjiv Khanna.
Place Of Incident: Jabalpur, Madhya Pradesh.
Judgment Date: 31-07-2020.

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