Mumbai: The Bombay High Court has emphasized the necessity of maintaining high educational standards, particularly in medical studies, while upholding the dismissal of an MBBS student. The student had challenged the annulment of his exam results and his disqualification from progressing to the second year.

A bench of Justices AS Chandurkar and Milind Sathaye ruled that the university’s regulations ensuring academic integrity in medical education were neither excessive nor unfair.

“Considering the undeniable need for maintaining the quality of education, especially in the field of medicine, where the candidate is aspiring to practice a noble profession, in our considered opinion, the punishment prescribed is appropriate and there is nothing harsh or disproportionate about it,” the court observed on January 27.

The petitioner, hailing from Odisha, Millan Pradhan, 20, is enrolled in the MBBS course at BJ Government Medical College, Pune. During the Winter-2022 first-year MBBS examinations, he wrote his mobile number on the answer sheets for Physiology-I and Anatomy-I. This was considered a violation of exam rules, as it could be interpreted as an attempt to influence the examiner.

Following an inquiry, the university’s Unfair Means Inquiry Committee penalised Pradhan under Ordinance 01/2014 by annulling his results in the concerned subjects and declaring him ‘fail.’ Pradhan later reappeared for the exams, clearing Physiology in the Summer-2023 session and Anatomy in Winter-2023. However, as per MUHS regulations, he could not advance to the second year since he had not passed all subjects on his first attempt.

His advocate, Hitesh Mishra, challenged Rule 71.12.12(b) of Ordinance 1/2024 and an MUHS advisory dated October 27, 2021, arguing they violated Article 14 (right to equality). He contended that medical students should be allowed to progress with pending subjects, similar to the “Allowed to Keep Term” (ATKT) provision applicable in later years.

Advocate Sachindra Shetye, appearing for MUHS, countered that first-year MBBS students must pass all subjects before moving forward, as per the Regulations on Graduate Medical Education (Amendment), 2019. The university stressed that a strong foundational understanding in the first year was crucial for advanced medical training.

The High Court upheld the university’s stance, emphasizing that strict academic standards were vital in medical education. It noted that ATKT was only applicable from the second to third year.

Rejecting Pradhan’s plea, the court ruled, “Unless a foundational first year of MBBS course is completed in all respects, including passing all subjects, a student cannot be permitted to undertake further training.”

Pradhan must now complete the mandatory 12-month training period after clearing his first-year exams before advancing to the second year.