“Don’t Punish Students for Institutional Lapses”: Rajasthan HC Regularizes Dental Admissions with Fine, Warns Colleges to ‘Desist from Irregular Admissions’
Isabella Mariam
The High Court of Rajasthan Single Bench of Justice Dinesh Mehta held that although the impugned order cancelling admissions was legally valid, the academic futures of the petitioners could not be irreversibly damaged due to administrative lapses of the admitting institutions. The Court directed regularization of the petitioners’ admissions upon payment of specified fines and instructed Rajasthan University of Health Sciences to issue mark sheets and degrees accordingly. The Court further imposed penalties on the concerned colleges and directed the Counseling Board to bar defaulting institutions if dues remain unpaid.
The petitions concerned a group of students admitted during academic sessions 2018–2019 and 2019–2020 to various dental colleges affiliated with the Rajasthan University of Health Sciences (RUHS), namely Vyas Dental College and Hospital, Eklavya Dental College, and Maharaja Ganga Singh Dental College. The petitioners had qualified the National Eligibility cum Entrance Test (NEET) and secured admission to Bachelor of Dental Surgery (BDS) courses.
However, the Dental Council of India (DCI) issued an order dated 3 December 2019 directing discharge of certain students on the grounds that their names were not uploaded on the DCI portal by the cut-off date of 15 September 2019 or that they were not registered with the Rajasthan NEET UG Counseling Board. This led to refusal to issue examination admit cards and eventual denial of mark sheets despite completion of coursework.
The petitioners submitted that they had been provisionally admitted by the colleges and paid the required fees. In S.B. Civil Writ Petition No. 1988/2021, petitioners Pooja Punaram Patel, Kanishka Sharma, and Harshita Sadhwani asserted that the omission of their names from the DCI list was solely due to inadvertence on the part of the college, which failed to upload their details before the cut-off date. The petitioners claimed that they only became aware of the DCI’s order when they were denied admit cards for their examinations.
In connected writ petitions, other students faced similar issues—either due to their names being uploaded after the cut-off date or due to their failure to register with the Counseling Board. All students involved had cleared NEET and had secured the required percentile for admission. The petitioners contended that the fault lay with the colleges and not with them.
The DCI and RUHS maintained that the admissions violated statutory regulations and were not regular. They contended that the petitioners had knowingly taken admission in violation of rules and should not be granted relief. The RUHS imposed a fine of ₹1 crore on the respondent-college, which was under separate challenge.
Counsel for RUHS and DCI submitted that leniency would set a poor precedent and proposed that the institutions be penalized severely for repeated infractions. They cited prior decisions of Division Benches where a fine of ₹25 lakh per student had been imposed in similar circumstances.
Justice Dinesh Mehta reviewed the factual record, including admission procedures, regulatory provisions, and correspondence between the institutions and regulatory authorities. The Court recorded:
“For whatever reasons—bonafide or otherwise—non-reflection of the names of the petitioners in the list of students uploaded on 15.09.2019 cannot be countenanced by this Court.”
On the issue of registration with the Counseling Board, the Court observed:
“Their admissions also cannot be claimed in tandem with law or treated regular in any event.”
However, in light of the petitioners’ academic performance and the fact that they had already completed the course, the Court stated:
“This Court feels that if their admissions are regularized, subject to payment of a token fine of Rs.1 lac each student… it would meet the ends of justice.”
On the responsibility of the admitting colleges, the Court recorded:
“It had given admissions to the students… irregularly. It ought to have been more vigilant and law-abiding while giving admissions.”
Citing the Supreme Court's ruling in Rajendra Prasad Mathur v. Karnataka University and a recent decision in Dr. Tanvi Behl v. Shrey Goel & Ors., the Court noted:
“We do not see why the appellants should suffer for the sins of the managements of these engineering colleges.”
Addressing a subset of students who appeared in NEET as General Category candidates but took admission under the OBC category, the Court stated:
“Since the petitioners were given admissions in the year 2018–2019 and have cleared the examination… they are also entitled for equitable considerations, however, on payment of slightly higher fine.”
On future compliance, the Court cautioned:
“In future, if any such irregular admission is given by the colleges… the DCI and RUHS shall take stern action… including revocation of recognition.”
The Court issued the following final directions:
“Though on merit, the order dated 03.12.2019 qua each of the student is affirmed, but on equity and subject to payment of Rs.1 lac by each student, their admissions stand regularized.”
“Each of the students shall furnish a demand draft of Rs.1 lac drawn in the name of Registrar, Rajasthan University of Health Sciences within a period of one month from today.”
“On receiving the demand draft and a webcopy of the order instant, the respondent – RUHS shall issue them mark-sheets/degrees.”
“After the degrees have been issued… the competent authority shall register the petitioners in accordance with law.”
“Colleges involved shall pay a fine of Rs.7 lac 50 thousand per student on or before 31.07.2025… In case of default, the Counseling Board shall not reflect name of such colleges in the list of eligible colleges.”
“Registrar, RUHS shall keep the amount in a separate account and transmit it to the Principal and Controller, Government Dental College, Jodhpur, to be utilized for capital expenditure purposes before 31.03.2026.”
“Petitioners Preya Sharma, Summera Reyaz, and Supriya Jaswal shall pay a fine of Rs.2 lac each and upon payment, their admissions shall be regularized.”
Advocates Representing the Parties
For the Petitioners: Mr. Manoj Bhandari, Senior Advocate assisted by Mr. Aniket Tater, Mr. Nikhil Dungawat
For the Respondents: Mr. S.S. Rathore, AAG assisted by Mr. Pravin Kumar Choudhary, Mr. A.A. Bhansali, Mr. Mahendra Bishnoi, Mr. Rajesh Punia, Mr. Sher Singh Rathore, Mr. Vipul Dharnia, Mr. Sanwar Lal, Deputy Government Counsel
Case Title: Pooja Punaram Patel & Ors. v. Rajasthan University of Health Sciences & Ors. and connected matters
Neutral Citation: 2025:RJ-JD:17403
Case Number: S.B. Civil Writ Petition No. 1988/2021 and connected cases
Bench: Justice Dinesh Mehta
[Read/Download order]
