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Dr. Pradeep Jain And Ors. vs Union Of India (Uoi) And Ors. on 22 June, 1984

86. Now there can be no doubt that the grievance made by the petitioners is justified. The petitioners are right when they contend that having regard to the fact that the house job was started by them prior to the delivery of the Judgment on 22nd June 1984, their admissions to the post graduate courses for the academic year 59 1985-86, that being the academic year for which they became due to be considered, should have been governed by the old rules which prevailed prior to the date of the Judgment and not by the new principle laid down in the Judgment. We have already started our reasons for taking this view and we need not reiterate those reasons. Of course the Principal of the Motilal Medical College cannot be blamed for granting admissions for the academic year 1985-86 in accordance with the new principle laid down by us in the Judgment, since we had said in our order dated 26th July 1984 that the Judgment shall be effective from the academic year 1985-86 and on a literal interpretation of that order even, admissions to the two year post graduate courses for the academic year 1985-86 would have to be in accordance with the new principle laid down in the judgment. But, as pointed out above, it would work considerable hardship and injustice if, in case of students who have started house job prior to the delivery of the Judgment on 22nd June 1984, admissions to the two year post graduate courses for the academic year 1985-86 were to be made on the basis of the rule enunciated in the Judgment. We must therefore hold that in the State of Uttar Pradesh and other States where the system of post graduate medical education adopted, is to have one year house job followed by two year post graduate course, students who started their house job prior to the delivery of the Judgment on 22nd June 1984 should be governed by the old rules prevailing prior to the date of the Judgment when seeking admission to the post graduate courses for the academic year 1985-86 but in case of students who started their house job after the date of the Judgment, their admissions to the post graduate courses for the academic year 1985-86 should be governed by the new principle laid down in the Judgment. On this view, 75% of the seats in the post graduate courses for the academic year 1985-86 should have been made available to the institutional students and the case of the petitioners was that, if that had been done, the petitioners would have been able to secure admission as falling within the 75% quota. It was not seriously disputed on behalf of the respondents that if the old rules governing admissions had been applied, the petitioners would, save perhaps in a solitary case, have been able to get admission to the post graduate courses. The petitioners were thus unjustly and improperly left out of the quota for institutional students on what was turned out to be erroneous view of the legal position. The petitioners also complained that even in regard to the 50% non-reserved seats, the petitioners were denied an opportunity of competing for them, because no entrance examination was held either by the Government of India or by the State Government or 60 even by the concerned University for testing the relative merits of the students seeking admission to the post graduate courses. This complaint was made in the alternative on the premise that the admissions were governed by the new principle laid down in the Judgment. We have already pointed out that this premise was unjustified and the admissions were governed not by the new principle laid down in the Judgment but by the old rules which prevailed prior to the delivery of the Judgment. But even if the admissions were governed by the new principle laid down in the Judgment, the Principal could not grant admissions to 50% non-reserved seats in the post graduate courses without judging the relative merits of the candidates through a common entrance examination. The Principal was clearly wrong in granting admissions to 50% non-reserved seats on the basis of the marks obtained by the candidates at the different M.B.B.S. examination held by different Universities. No admissions could be granted to 50% non-reserved seats except through a common entrance examination where the relative merits of the candidates could be tested and a comparative evaluation could be made on the basis of a common standard. It is quite possible that if a common entrance examination had been held, the petitioners or at least some of them might have been able to establish their superior merit as against those who happen to have been admitted on the basis of the marks obtained at the different M.B.B.S. examinations. We are therefore of the view that the admissions purported to have been made to 50% non-reserved seats in the post graduate courses were invalid and the admissions should have been made in accordance with the old rules prevailing prior to the delivery of the Judgment on 22nd June 1984.
Supreme Court of India Cites 23 - Cited by 215 - P N Bhagwati - Full Document

Jagdish Saran & Ors vs Union Of India & Ors on 28 January, 1980

We pointed out that in the result "at least 30 per cent of the open seats shall be available for admission of students on All India basis irrespective of the State or University from which they come" and directed that "such admissions shall be granted purely on merit on the basis of either All India Entrance Examination or entrance examination to be held by the State". This was the decision given by us in regard to admissions to the MBBS and BDS courses. We proceeded to discuss the question of admissions to post graduate courses such as MD, MS and the like. We I earned heavily on the observations made by Krishna Iyer J. in Jagdish Saran v. Union of India(1) as also on the recommendation by the Indian Medical Council and the opinion expressed by the Medical Education Review Committee where an opinion was clearly expressed that admissions to post graduate courses in any institution should be guided strictly by merit and should be open to candidates on all India basis. We also referred to the policy statement of the Government of India filed by the learned Attorney General where 48 the view was expressed categorically by the Government of India that so far as admissions to the institutions of post graduate colleges and such professional colleges are concerned, they should be entirely on the basis of all India merit, subject only to Constitutional reservations in favour of scheduled castes and scheduled tribes However, taking into account broader considerations of equality of opportunity and institutional continuity in education which has its own importance and value, we took the view that though residence requirement within the State should not be a ground for reservation in admissions to post graduate courses, a certain percentage of seats may in the present circumstances, be reserved on the basis of institutional preference "in the sense that a student who has passed M.B.B.S. course from a medical college may be given preference for admission to post graduate course in the same medical college or University but such reservation on the basis of institutional preference should not in any event exceed 50% of the total number of open seats available for admission to the post graduate course."
Supreme Court of India Cites 12 - Cited by 261 - V R Iyer - Full Document
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