Summary
MCI assessors conducting compliance verification were not confined to previously identified deficiencies and could examine other shortcomings affecting medical-education standards. Nevertheless, the Central Government’s refusal of renewal required reasons. The Court directed another hearing and an informed decision with Oversight Committee assistance, without granting fresh admissions itself.
Issues
- Whether compliance verification was a limited remand preventing assessment of new deficiencies.
- Whether the unreasoned renewal refusal required reconsideration.
Provisions considered
- Section 10A(7), Indian Medical Council Act, 1956Requires regard to minimum educational standards and adequate staff, equipment, hospital and training facilities in the recommendation and approval process. (¶¶ 25, 29)
Held
- An institution must remain compliant, and assessors cannot ignore other observed deficiencies merely because the matter was returned for compliance verification. Civil-procedure distinctions between open and limited remand did not govern this statutory inspection exercise. (¶ 23–29)
- Courts ordinarily respect expert assessment, subject to cogent review grounds, while the Central Government must act objectively and give reasons. Its impugned order lacked the requisite reasoned consideration. (¶¶ 19–22, 29–30)
- The Government was to afford further hearing, obtain assistance from the newly constituted Oversight Committee and decide within two weeks. Existing students’ continued education was recorded; new-batch permission was not judicially granted. (¶¶ 30, 32)
Result
Directions issued for a reasoned Central Government decision within two weeks after further hearing and Oversight Committee assistance. Matter retained for 24 August 2017.