Summary
A medical college argued that confirmation of its 2016–2017 renewal and return of its guarantee required permission to admit students in 2017–2018. The Court distinguished renewal from recognition, declined to reweigh expert findings and granted no admission relief for 2017–2018. It directed processing of recognition for 2018–2019 following inspection and an opportunity to remedy deficiencies.
Issues
- Whether confirmation of renewal for an earlier batch entitled the college to recognition and subsequent admissions.
- Whether different findings in successive inspections or clerical errors invalidated the decision.
- What prospective regulatory process should follow.
Held
- Confirmation of renewal under Section 10A for 2016–2017 did not automatically confer recognition under Section 11(2) from 2017–2018. The proposals involved distinct purposes and standards; the Government had accepted renewal while refusing subsequent admission and recognition. (¶¶ 11–16, 20)
- Variation between inspection findings could reflect conditions on different dates and did not itself discredit the later report. Satisfaction about explanations and minimum bed occupancy belonged to the expert bodies; judicial review was not an appeal on those assessments. (¶ 16–17)
- The February/March assessments concerned renewal compliance, whereas the April assessment concerned recognition. The objection to successive surprise inspections confused the two processes. An admitted clerical inclusion of another inspection’s chart did not vitiate the otherwise supported decision. (¶ 18–20)
- The Court found no merit in the existing challenge and deemed the pending Madras writ petition disposed of. The recognition proposal was to be treated as one for 2018–2019; MCI had to inspect within two months, notify deficiencies, allow rectification and consider compliance before recommendation. The Government was to decide within one month thereafter and promptly communicate its decision. (¶ 21–23)
Result
Appeal and application disposed of with no 2017–2018 admission relief; pending High Court writ deemed disposed of. Recognition proposal to be processed for 2018–2019 under the specified inspection, rectification and decision procedure. No costs.