In a pivotal judgment that upholds the rights of persons with disabilities, the Supreme Court of India has quashed the denial of admission to an MBBS aspirant with locomotor and speech disabilities, declaring the existing medical guidelines discriminatory and “reeking of ableism.”
The judgment, delivered by a Bench comprising Justice B.R. Gavai and Justice K.V. Viswanathan in Anmol v. Union of India (Civil Appeal No. 14333 of 2024), set aside the Punjab and Haryana High Court’s dismissal of the petition challenging the rejection of admission. The Supreme Court not only upheld the student’s right to study medicine but also directed the National Medical Commission (NMC) to revise its regulations to align with the principles of inclusivity and reasonable accommodation.
Case Background
The appellant, Anmol, a student with a stellar academic record, cleared the NEET-UG 2024 examination with an outstanding rank of 2462 in the Persons with Disability (PwD) category, surpassing the cut-off for the OBC-PwD quota. However, his application was rejected by the Disability Assessment Board at the Government Medical College, Chandigarh, which declared him ineligible based solely on his quantified disability percentage.
Anmol suffers from a 50% locomotor disability with club foot in his right lower limb and phocomelia affecting his hands, in addition to a 20% speech and language disability. The cumulative disability was calculated at 58%. Despite this, the assessment board denied him eligibility without conducting a functional competency test.
After the Punjab and Haryana High Court upheld this decision, Anmol approached the Supreme Court, seeking a writ of certiorari to quash the disability certificate and obtain a fresh assessment.
Key Legal Issues
Validity of the NMC Guidelines: The court scrutinized the medical regulations that prescribe “both hands intact” as an essential criterion for pursuing an MBBS degree. It found such criteria to be violative of the Right of Persons with Disabilities Act, 2016 (RPwD Act), which mandates functional assessment and reasonable accommodation for disabled persons.
Purposive Interpretation of Disability Laws: The judgment reaffirmed the doctrine of purposive interpretation, holding that quantification of disability alone cannot be a ground for disqualification without considering the candidate’s ability to function with assistive devices and accommodations.
Application of Constitutional Rights: The court ruled that a mechanical rejection based on outdated medical standards is unconstitutional as it violates the right to equality (Article 14) and the right to education (Article 21-A).
Supreme Court’s Observations
Rejecting the opinion of the five-member medical board, which had denied eligibility based on existing NMC guidelines, the Supreme Court noted that the guidelines “perhaps need revision” and were “unable to accommodate the advancements in medical education and assistive technology.”
Justice K.V. Viswanathan, writing for the Bench, observed:
“The prescription of ‘both hands intact’ reeks of ableism and has no place in statutory regulations. It glorifies a notion that persons with typical abilities are somehow superior. Such an approach is contrary to Article 41 of the Constitution and the principles of the United Nations Convention on the Rights of Persons with Disabilities.”
The court relied extensively on previous landmark rulings, including Omkar Ramchandra Gond v. Union of India (2024 SCC OnLine SC 2860) and Om Rathod v. Director General of Health Services (2024 SCC OnLine SC 3130), which emphasized functional assessment over rigid disability classifications.
In rejecting the report of the five-member AIIMS medical board, the court commended the dissenting opinion of Dr. Satendra Singh, who assessed the candidate’s ability to perform essential medical tasks using assistive technology. His report highlighted:
“Anmol can successfully navigate the MBBS course with clinical accommodations and assistive technologies. At this stage, we should not assume incompetence without first providing opportunities in a simulated lab and ensuring access to necessary accommodations.”
Court’s Directions
The Supreme Court issued the following orders:
Confirmation of Admission: The court upheld its interim order dated December 12, 2024, directing that Anmol be admitted to the Government Medical College, Sirohi, Rajasthan.
Reform of NMC Guidelines: The NMC was directed to submit revised disability assessment guidelines before March 3, 2025, ensuring functional evaluation rather than arbitrary rejection.
Judicial Oversight on Disability Assessments: The court emphasized that Disability Assessment Boards must provide specific reasoning when declaring a candidate unfit and that all negative assessments will be subject to judicial review.
This decision is expected to have far-reaching implications for disability rights in India, ensuring that persons with disabilities are not arbitrarily excluded from professional courses due to outdated and discriminatory regulations.
As the court aptly stated:
“The approach should not be to disqualify candidates but to explore how best to accommodate them in realizing their educational aspirations.”
