1999 (8) TMI 959 - SC - Indian Laws

Issues Involved:
1. Legislative Competence and Standards in Medical Education
2. Role of Medical Council of India (MCI)
3. Role of States in Short-listing Admissions to Postgraduate Courses
4. Minimum Qualifying Marks for Reserved Categories
5. Impact on Standards of Education

Summary:

1. Legislative Competence and Standards in Medical Education:
The court examined the interplay between Entry 66 of List I and Entry 25 of List III. Entry 66 of List I pertains to the "Coordination and determination of standards in institutions for higher education," while Entry 25 of List III includes "Education, including technical education, medical education, and universities." The court held that while states can regulate admissions, they cannot impinge on the standards set by the Union under Entry 66 of List I. The Indian Medical Council Act, 1956, and the regulations framed under it are binding and must be adhered to by the states.

2. Role of Medical Council of India (MCI):
The court emphasized that the MCI has the authority to prescribe standards of postgraduate medical education u/s 20 of the Indian Medical Council Act, 1956. These standards are not merely advisory but binding. The MCI's regulations, including those on minimum qualifying marks, must be followed by all medical institutions and state authorities.

3. Role of States in Short-listing Admissions to Postgraduate Courses:
The court clarified that states have the power to short-list eligible candidates for postgraduate medical courses through entrance tests. However, this power is subject to the standards set by the MCI. States can prescribe additional qualifications but cannot dilute the standards set by the MCI.

4. Minimum Qualifying Marks for Reserved Categories:
The court held that while states can prescribe lower qualifying marks for reserved categories, such dilution must be reasonable and within permissible limits. The court stated that the maximum permissible dilution is 50% of the qualifying marks for general category candidates. For example, if the qualifying marks for general candidates are 50%, the minimum qualifying marks for reserved categories can be reduced to 25%.

5. Impact on Standards of Education:
The court noted that the quality of education is significantly impacted by the calibre of students admitted. Lowering the qualifying marks excessively for reserved categories could compromise the standards of education. The court emphasized that at higher levels of education, such as postgraduate and super-speciality courses, merit must be prioritized to maintain high standards of education and public interest.

Conclusion:
1. States can regulate admissions but must adhere to MCI standards.
2. MCI's regulations on postgraduate medical education are binding.
3. States can prescribe additional qualifications but cannot dilute MCI standards.
4. Lowering qualifying marks for reserved categories is permissible but must be reasonable.
5. Excessive lowering of qualifying marks can compromise educational standards.

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