Pranav B Prem

In a significant ruling, the Rajasthan High Court's Jodhpur bench dismissed a batch of petitions filed by medical students who were barred from appearing in their examinations due to insufficient attendance. The Court reaffirmed that adherence to minimum attendance requirements in medical education is crucial, as it directly impacts public healthcare standards.

Court’s Observations on Medical Education and Attendance

Justice Vinit Kumar Mathur, while dismissing the petitions, emphasized the necessity of maintaining high educational standards for future medical professionals, stating: "In the considered opinion of this Court, attendance in the MBBS examination is crucial. If a student has not acquired the requisite attendance in both theory and practicals, it would be detrimental to allow them to proceed with the course, particularly for the second-year examination. The MBBS degree is intended for those who will eventually treat human beings, making it of significant importance."

The Court emphasized that students pursuing a professional degree like MBBS must meet the requisite attendance criteria to ensure they acquire the necessary knowledge and practical skills to become competent healthcare practitioners. "Medical education requires strict adherence to attendance to ensure that students are sufficiently equipped with the knowledge and practical skills to become competent practitioners. In this regard, the Court recognizes the petitioner’s role as a future healthcare provider and acknowledges the responsibility they will have in influencing the well-being of the community."

Facts of the Case

The lead petition was filed by a student who had qualified the NEET examination and was admitted to the MBBS course in Government Medical College, Barmer, for the academic year 2023. While in the first year, the petitioner was diagnosed with dengue and was unable to attend the required number of classes, leading to a shortfall in attendance below the prescribed 75% in theory and 80% in practical and clinical sessions. The petitioner contended that his absence was due to medical reasons beyond his control and that he should have been allowed to appear in the supplementary examination instead of being forced to lose an academic year. The respondents, however, argued that the attendance criteria are mandated by regulations and that since the petitioner had not appeared in the main examination due to low attendance, he was ineligible for the supplementary examination as well.

The Court highlighted the importance of maintaining academic rigor, particularly in fields like medicine, which have a direct impact on public health. It observed: "The importance of maintaining the highest standards in medical education cannot be overstated, as it directly affects the quality of healthcare provided to the public at large. A society that allows widespread incompetency cannot thrive, and therefore, educational standards must not be allowed to be degraded to substandard levels." The Court further noted that the attendance regulations were put in place to ensure that students receive adequate training before being entrusted with human lives. Citing the necessity of academic excellence, the Court stressed: "Every nation must strive for academic excellence, especially in fields like medicine, which have a direct impact on public health."

Ruling of the Court

Considering that the petitioner did not complete the mandatory attendance requirements and that a stay application had already been dismissed by a coordinate bench, the High Court denied relief to the petitioners, ruling: "Since the petitioner has not completed the requisite number of attendance for theory and practical and stay application of the petitioner has also been dismissed by a coordinate bench of this court vide its order dated 22.10.2024, therefore, no relief can be granted to the petitioners at this stage." Thus, the petitions were dismissed

Cause Title: Surendra Bisnoi v State of Rajasthan & Ors, and other connected petitions

Case No: S.B. Civil Writ Petition No. 17615/2024

Bench: Justice Vinit Kumar Mathur

[Read/Download order]