Introduction:

The Supreme Court of India, in the matter of Vaidya Jayant Yashwant Deopujari vs. Ved Prakash Tyagi and National Commission for Indian System of Medicine vs. Ved Prakash Tyagi [Diary Nos. 32061/2025 & 32087/2025], on June 10, 2025, stayed a recent judgment passed by the Delhi High Court that had quashed the appointment of Dr. Vaidya Jayant Yashwant Deopujari as the Chairperson of the National Commission for Indian System of Medicine (NCISM). The High Court had ruled that Dr. Deopujari was ineligible under Section 4(2) of the NCISM Act, 2020 due to the absence of a postgraduate degree in Indian Systems of Medicine. The matter, now taken up by the Supreme Court on appeal, hinges upon the interpretation of academic qualifications, particularly whether a Ph.D. conferred directly after graduation can be equated with a postgraduate degree for the purpose of statutory eligibility. A Bench comprising Justice Prashant Kumar Mishra and Justice Manmohan issued notice on the special leave petitions and granted an interim stay to ensure Dr. Deopujari is not deprived of retiral benefits, considering that his term was set to end the same day.

Arguments of the Petitioners (Deopujari and NCISM):

Dr. Vaidya Jayant Deopujari, represented through the Special Leave Petition, contended that the Delhi High Court had taken a narrow and overly rigid view of educational qualifications. He submitted that while he may not hold a traditional postgraduate degree like an M.D. in Ayurveda or other Indian Systems of Medicine disciplines, he had earned a Ph.D. in the same stream, which ought to be treated as an equivalent or higher academic qualification. It was argued that his Ph.D. entailed rigorous research work in the field of Ayurveda and was awarded by a recognised university. The petitioners further submitted that the statutory requirement should be interpreted purposively and not mechanically, especially considering that the Act aims to promote excellence in education, which may well include persons with research backgrounds. Additionally, it was pointed out that Dr. Deopujari has had a distinguished career in the domain of Indian medicine, having held top academic and regulatory posts, and that disqualifying him purely on the basis of a formal degree nomenclature undermines both the spirit of the legislation and the candidate’s demonstrated contribution. The petition also raised concerns regarding the impact of the Delhi High Court’s judgment on his pension and retiral benefits, as the order was passed just before his term ended, potentially depriving him of post-retirement entitlements. Moreover, the NCISM, through its own petition, reinforced these arguments and stressed that the qualification norms should be interpreted with due regard to equivalent learning outcomes and professional expertise.

Arguments of the Respondents (Tyagi and Sharma):

The original writ petitions before the Delhi High Court, filed by Dr. Ved Prakash Tyagi and Dr. Raghunandan Sharma, had sought a writ of quo warranto against Dr. Deopujari’s appointment. The core contention was that he did not possess the minimum statutory qualification under Section 4(2) of the NCISM Act, 2020, which mandates that the Chairperson of the Commission must hold a postgraduate degree in any discipline of the Indian System of Medicine. The respondents strongly argued that a Ph.D. cannot, under any reasonable academic interpretation, be equated with a postgraduate degree. They contended that postgraduate degrees, like MD or MS in Ayurveda or Unani, require structured academic coursework and rigorous examinations, whereas a Ph.D., while higher in the academic hierarchy, is a research degree and not designed as a substitute for postgraduate study. The petitioners pointed out that Dr. Deopujari had received his Ph.D. directly after his graduation and not after completing a recognised postgraduate program. Thus, in their view, the very foundation of eligibility under the statute was lacking. They argued that permitting such appointments would dilute academic and professional standards and would set a dangerous precedent for future regulatory bodies. Furthermore, they emphasised that appointments to statutory commissions must strictly comply with the letter and spirit of the enabling legislation.

Delhi High Court’s Judgment (June 6, 2025):

A Division Bench of the Delhi High Court comprising Chief Justice DK Upadhyay and Justice Tushar Rao Gedela held that Dr. Deopujari’s appointment as Chairperson of NCISM was invalid due to non-fulfilment of statutory eligibility criteria. The Court interpreted Section 4(2) of the NCISM Act, 2020 to require a formal postgraduate degree in the Indian System of Medicine, such as an MD or equivalent. The judgment examined the nature and structure of Ph.D. qualifications and held that a Ph.D., while a higher research qualification, does not constitute a “postgraduate degree” within the meaning of the statute, particularly when awarded directly after a bachelor’s degree. The High Court observed that a postgraduate degree involves a structured course of study followed by prescribed examinations, whereas a Ph.D. is primarily focused on original research without formal academic coursework or traditional examinations. It further noted that in India’s higher education system, the term “postgraduate” is specifically and traditionally associated with Master’s degrees, such as MA, MSc, MD, or MS. The Court opined that allowing a Ph.D. earned without a prior Master’s degree to qualify as a postgraduate qualification would violate the uniform standards of education envisaged by the Act. Accordingly, it quashed the appointment of Dr. Deopujari, concluding that he lacked the eligibility mandated under Section 4(2). The Court emphasised that appointments to such significant regulatory roles must conform strictly to the statutory qualifications to uphold the credibility and integrity of the Commission.

Supreme Court’s Interim Order (June 10, 2025):

The Supreme Court Bench led by Justice Prashant Kumar Mishra and Justice Manmohan, while hearing the Special Leave Petitions, issued notices to the respondents and stayed the Delhi High Court’s judgment. The Bench clarified that the interim relief was granted, primarily because Dr. Deopujari was demitting office the same day and would otherwise suffer irreparable loss in terms of pensionary and retiral benefits. The Court made it clear that it had not expressed any opinion on the merits of the High Court’s ruling and that the question of law involved—whether a Ph.D. conferred after graduation could be considered as a “postgraduate qualification” under the Act—would be examined during the final hearing. Justice Mishra observed during the hearing that this was a complex academic question that warranted a deeper examination of educational norms, equivalence parameters, and legislative intent. The Court seemed inclined to consider whether the statute’s purpose might be served by allowing candidates with demonstrable academic merit and research expertise, even if they do not hold a traditional postgraduate degree. The interim stay effectively preserves Dr. Deopujari’s status for the purposes of retiral entitlements and also prevents immediate vacancy-related complications at the NCISM.