Safiya Malik

The High Court of Delhi Single Bench of Justice Jasmeet Singh has quashed the All India Institute of Medical Sciences’ decision cancelling the candidature of an aspirant who secured a top rank in the INI-SS entrance examination for admission to the DM (Critical Care Medicine) course. The Court held that the requirement of 1,095 days of postgraduate residency can be satisfied cumulatively across different recognised institutions when the governing prospectus does not stipulate that the training must be completed in a single institute. It found that AIIMS could not introduce an additional eligibility condition at the final stage of the admission process to reject the candidature on the ground of fragmented residency tenure and accordingly set aside the rejection letter.

The case arose from the cancellation of a candidate’s candidature for admission to a super-specialty medical programme. The petitioner had applied for admission to the DM Critical Care Medicine course conducted through the Institute of National Importance Super-Specialty Entrance Test for the January 2026 session. The eligibility condition required completion of three years of postgraduate residency, amounting to 1,095 days, by the prescribed cut-off date.

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The petitioner had completed postgraduate residency training in Anaesthesiology across three recognised medical institutions through successive rounds of authorised counselling. The cumulative duration of residency exceeded the prescribed requirement. The petitioner was awarded an MD degree by the concerned university, which certified completion of the required tenure in accordance with applicable medical education regulations.

Despite qualifying the entrance examination and being provisionally considered eligible throughout multiple stages of the selection process, the petitioner’s candidature was later cancelled by the examining institution on the ground that the residency experience had been acquired from multiple institutions rather than from a single institute.

The petitioner challenged the rejection, contending that neither the prospectus nor the governing postgraduate medical education regulations mandated completion of residency from a single institution. The respondents defended the rejection by asserting institutional discretion in interpreting eligibility conditions and contending that fragmented residency undermined training standards.

The Court examined the scope of judicial review in academic matters and the interpretation of eligibility conditions under the governing prospectus and regulations. It observed that “the core controversy in the present petition is with respect to the question, whether the mandatory requirement of 1095 days in total can be considered as satisfied when the tenure is completed in piecemeal at different institutions.”

While acknowledging judicial restraint in academic policy, the Court recorded that “courts must be slow and reluctant to interfere in education matters as a rule of prudence, but at the same time the Court retains its power of judicial scrutiny when any arbitrary decision is in question.”

On interpretation of the eligibility clause, the Court stated that “a plain and conjoint reading of both, the Clause 4.3.2 and the regulation 2.1, shows that it requires requisite qualification, degree and tenure being 3 years by the prescribed date.” It further noted that “the aforesaid Clause is totally silent on the fact that the 3 year requirement has to be from a single institute or the same can be considered when fragmented in durations.”

Rejecting the respondents’ contention of an implied requirement, the Court observed that “any eligibility condition must be clear, explicit and uniformly applicable.” It further recorded that “once the language of prospectus is clear and unequivocal, it cannot be left to the discretion of the respondent Institution to add words and interpret in a way which is not borne out from the plain reading.”

The Court also took note of the petitioner’s uninterrupted participation in the selection process and recorded that “the respondent Institution did not object at any time prior that the residency experience of the petitioner was violative of Clause 4.3.2 of the prospectus.” It found that the impugned action “lacks the essence of justifiability” and did not meet the standard of judicial scrutiny applicable to academic decisions.

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The Court held that “the petitioner’s tenure even if physically fragmented in parts totalling to 1095 days in the same discipline falls within the parameters of Clause 4.3.2 of the prospectus. The impugned rejection letter dated 02.01.2026 is hereby quashed and set aside. The petition is allowed in the aforesaid terms,”

Advocates Representing the Parties

For the Petitioner: Ms. Anushree Kapadia, Advocate; Mr. Pranay Bhardwaj, Advocate; Mr. Shivank Singh, Advocate

For the Respondents: Mr. Anand Varma, Advocate; Mr. Ayush Gupta, Advocate; Mr. Kanav Vir Singh, Senior Panel Counsel; Mr. Siddharth Garg, Advocate; Mr. Himanshu Chaubey, Advocate; Mr. Srijan Sinha, Advocate; Ms. Lihzu Shiney Konyak, Advocate; Mr. Srajan Yadav, Advocate; Ms. Trisha Garimala, Advocate; Mr. Kapil Midha, Advocate; Ms. Muskaan Garg, Advocate; Mr. T. Singhdev, Advocate; Mr. Abhijit Chakravarty, Advocate; Mr. Tanishq Srivastava, Advocate; Mrs. Yamini Singh, Advocate; Mr. Vedant Sood, Advocate

Case Title: Meet Bhadresh Shah v. All India Institute of Medical Sciences & Ors.

Neutral Citation: 2026: DHC:823

Case Number: W.P.(C) No. 78 of 2026

Bench: Justice Jasmeet Singh