The present case concerns the delicate balance between regulatory oversight in medical education and the rights of institutions to admit students when allegations of irregularities arise. At its heart lies a conflict: whether the mere registration of a First Information Report (FIR) against a medical college can justify withdrawing its approval to admit students, notwithstanding existing infrastructure and compliance with statutory norms.
The case also examines the boundaries of judicial intervention at the interim stage—particularly whether a single judge of the High Court could direct the inclusion of a medical college in the ongoing NEET-UG counselling despite the National Medical Commission (NMC) having withdrawn its earlier conditional renewal of seats.
Case Title: National Medical Commission v. Index Medical College, Hospital and Research Centre & Ors.
Court: High Court of Delhi
Citation: LPA 564/2025 & CM APPL. 55755-58/2025
Bench: Chief Justice Devendra Kumar Upadhyaya and Justice Shalinder Kaur
Date of Judgment: 04 September 2025
Factual Background
Parties Involved
- The appellant, NMC, is the statutory regulator under the National Medical Commission Act, 2019.
- The respondent no.1, IMCHRC, is a private medical institution offering MBBS courses with sanctioned intake of 250 seats.
Grant of Renewal (2024–25)
For the academic year 2024–25, NMC’s Undergraduate Medical Education Board (UGMEB) granted renewal of 250 MBBS seats to IMCHRC, subject to fulfillment of statutory conditions under the 2019 Act and allied regulations. Admissions were accordingly made.
Deficiency Notice and Conditional Renewal (2025–26)
- On 25 April 2025, NMC sought additional information from IMCHRC.
- Based on expert evaluation, deficiencies were noted and a show cause notice (11 May 2025) was issued.
- IMCHRC submitted compliance.
- On 27 June 2025, NMC conditionally renewed 250 MBBS seats for the academic year 2025–26, granting 4 months for rectification of deficiencies.
FIR and Withdrawal of Renewal
- On 30 June 2025, an FIR was lodged against IMCHRC, alleging criminal conspiracy, corruption, fabrication of evidence, breach of secrecy protocols, and manipulation of NMC’s assessment process.
- On 17 July 2025, NMC withdrew its conditional renewal with immediate effect, citing the FIR and potential risks to the integrity of medical education.
Writ Proceedings Before a Single Judge
- IMCHRC filed W.P.(C) No.10890/2025, challenging the withdrawal order.
- On 22 August 2025, the Single Judge allowed the institution to participate in ongoing NEET-UG counselling, directing inclusion of its name in the college list.
- NMC appealed against this interim order under Clause X of the Letters Patent.
Arguments
Appellant (NMC)
1) Impermissible Interim Relief
- The Single Judge’s interim order effectively allowed admissions despite NMC’s withdrawal, contrary to Supreme Court precedents (MCI v. KIMS, (2016) 11 SCC 530).
- Interim directions permitting admissions undermine regulatory safeguards and may jeopardize students’ futures.
2) Serious Allegations in FIR
- FIR alleged conspiracy, corruption, fabrication, and illegal gratification—striking at the root of regulatory integrity.
- Allowing admissions amid investigation would endanger public health standards.
3) Misplaced Reliance on Madhuri Sewa Nyas
- The Single Judge relied on NMC v. Madhuri Sewa Nyas (SLP (C) 15865/2025, SC order 21 July 2025), where the Supreme Court held that FIR registration alone is not a ground to deny permission.
- However, the Judge ignored para 8 of that judgment, which required NMC to conduct fresh inspection and satisfy itself before allowing admissions.
Respondent (IMCHRC)
1) FIR Alone Not Ground for Withdrawal
- The only reason cited in NMC’s withdrawal order (17 July 2025) was the FIR.
- The Supreme Court in Madhuri Sewa Nyas held FIR registration per se cannot justify denial if infrastructure exists.
2) Better Case than Madhuri Sewa Nyas
- Unlike in Madhuri Sewa Nyas (where renewal was pending), here NMC had already granted renewal (27 June 2025).
- Thus, withdrawal based solely on FIR was arbitrary.
3) Students’ Interest
- Denying participation in counselling harms prospective students, despite the institution’s compliance.
- NMC itself had earlier found the institution suitable, albeit conditionally.
Court’s Analysis
Grounds for Withdrawal
- The 17 July 2025 order shows only the FIR as the reason for withdrawal.
- No fresh deficiency finding was cited.
Applicability of Madhuri Sewa Nyas
- Facts were similar: same FIR of 30 June 2025 was in issue.
- SC held FIR cannot alone justify withholding permission if norms are met.
- However, SC also directed NMC to conduct inspection and decide afresh.
Error of Single Judge
- While correctly applying paras 5 and 7 of Madhuri Sewa Nyas, the Single Judge ignored para 8, which mandated fresh inspection before admissions.
- Hence, interim direction allowing admissions was beyond jurisdiction.
Lenient Conditional Renewal
- NMC’s 27 June 2025 conditional renewal was itself questionable.
- The court observed that leniency cannot be allowed in medical education, as inadequately trained doctors risk human lives.
- Renewal must be based on strict compliance with infrastructure norms.
Need for Timely Decision
Considering counselling schedules (10–19 Sept 2025; 30 Sept–10 Oct 2025; stray vacancies 16–18 Oct 2025), the Court directed expeditious inspection and decision before 9 September 2025.
Final Directions
The Division Bench disposed of the appeal and writ with the following directions
Fresh Inspection
- NMC to secure a fresh inspection report from an Expert Committee by 09.09.2025.
- Based on the report, NMC to decide whether IMCHRC can admit students for 2025–26.
Conditional Participation in Counselling
- If NMC is satisfied with compliance, adequate students (as per merit) must be allotted through counselling against sanctioned seats.
FIR Proceedings Unaffected
- The directions do not affect the CBI investigation or trial, which shall proceed independently.
No Leniency Principle
- NMC must strictly ensure infrastructure and statutory compliance; lenient renewals are impermissible.
Significance of the Judgment
Clarifies Effect of FIRs on Medical Institutions
- FIR alone cannot justify withdrawal of permission unless deficiencies in infrastructure exist.
- Protects institutions from arbitrary denial while safeguarding regulatory integrity.
Affirms Supreme Court Precedent
- Reinforces Madhuri Sewa Nyas while emphasising complete adherence, including fresh inspection before allowing admissions.
Student Welfare v. Regulatory Integrity
- Balances students’ right to education with need to ensure quality medical training.
- Prevents disruption of counselling timelines while insisting on compliance.
Judicial Approach to Interim Relief
- High Courts must avoid interim directions permitting admissions without compliance verification.
- Reiterates that such relief can have irreversible consequences.
Policy Implication
- Establishes strict “no leniency” approach in medical education approvals.
- Encourages transparency and accountability in NMC’s decision-making.
Conclusion
Delhi High Court’s judgment in National Medical Commission v. Index Medical College, Hospital and Research Centre underscores the fine balance between regulatory vigilance and institutional rights in medical education. While the Court acknowledged that an FIR cannot, by itself, justify denial of admissions, it firmly reiterated that medical education cannot be subjected to leniency or compromise. Institutions entrusted with training future doctors must strictly meet infrastructure and statutory requirements, and any deviation risks undermining public health.
The ruling harmonises the Supreme Court’s directions in Madhuri Sewa Nyas with the realities of ongoing counselling, ensuring that student interests are not unfairly prejudiced while preserving the integrity of the regulatory process. By mandating a fresh inspection and requiring NMC’s satisfaction before admissions, the Court struck a measured middle path—neither permitting arbitrary exclusion of a college, nor allowing blind participation without compliance.
In broader terms, the case highlights that judicial intervention in medical education must remain cautious, especially at interim stages, since directions relating to admissions can have far-reaching and often irreversible consequences. Ultimately, the decision affirms that the quality of medical training is inseparably linked with the protection of human life, and therefore, strict adherence to statutory norms is non-negotiable.
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