Introduction:

In a compelling and unusual legal development, the Supreme Court of India recently intervened in the controversy surrounding the appointment of Dr. Vaidya Jayant Yeshwant Deopujari as Chairperson of the National Commission for Indian System of Medicine (NCISM), following a Delhi High Court judgment that had quashed his appointment. The matter reached the apex court in Vaidya Jayant Yashwant Deopujari vs. Ved Prakash Tyagi and National Commission for Indian System of Medicine vs. Ved Prakash Tyagi, registered under Diary Nos. 32061/2025 and 32087/2025 respectively. The Delhi High Court had ruled that Dr. Deopujari did not fulfill the eligibility requirement laid down under Section 4(2) of the NCISM Act, 2020, as he did not hold a postgraduate degree in any discipline of the Indian System of Medicine. Although he held a Ph.D., it was conferred directly after graduation and not following a postgraduate qualification. The High Court held that a Ph.D. is a research qualification and not equivalent to a postgraduate degree such as MD or MS. The Supreme Court Bench comprising Justice Prashant Kumar Mishra and Justice Manmohan stayed this judgment on June 10, 2025, primarily to protect Dr. Deopujari from being deprived of his retiral and pension benefits, as his term concluded the same day. The Supreme Court will now examine the broader legal question of whether a Ph.D. earned without a master’s degree can meet the statutory standard of a “postgraduate qualification” under Indian regulatory frameworks for appointments to statutory commissions.

Arguments of Both Sides:

The case revolves around the interpretation of the statutory requirement under Section 4(2) of the National Commission for Indian System of Medicine Act, 2020, which mandates that the Chairperson of NCISM must possess a “postgraduate degree in any discipline of Indian System of Medicine.” The petitioners before the Delhi High Court, Dr. Ved Prakash Tyagi and Dr. Raghunandan Sharma, sought a writ of quo warranto against Dr. Deopujari, challenging the legality of his appointment on the ground that he did not fulfill this educational qualification. Their argument was that Dr. Deopujari had obtained a Ph.D. directly after graduation, thereby lacking the intermediary postgraduate (master’s level) qualification required by law. They contended that Indian higher education frameworks distinctly categorize postgraduate degrees as structured programs like MD, MS, MA, or MSc, which involve formal coursework and examinations. They emphasized that a Ph.D., although higher in academic hierarchy, is a research-based credential and not synonymous with a postgraduate degree, especially when not preceded by one. On the other hand, Dr. Deopujari and the NCISM challenged this narrow interpretation by filing Special Leave Petitions in the Supreme Court. They submitted that the statute should be interpreted in a purposive manner to accommodate individuals who have made significant scholarly contributions to Indian Systems of Medicine, even if they do not possess the formal qualification of an MD or equivalent. They argued that his Ph.D., awarded by a recognized university, demonstrates academic rigor, expertise, and research excellence in the field, and thus meets the spirit of the eligibility criterion. Furthermore, they emphasized Dr. Deopujari’s long-standing contribution to the field, his leadership, and his service in several key roles, suggesting that disqualifying him on a technicality would undermine the integrity and mission of NCISM.

Judgement:

When the matter came before the Delhi High Court, the bench comprising Chief Justice DK Upadhyay and Justice Tushar Rao Gedela delivered a comprehensive ruling. The Court held that the statutory language of “postgraduate degree” carries a specific academic meaning, particularly within Indian higher education regulations. It observed that a postgraduate degree implies the completion of a prescribed course of study with associated examinations, typically earned after obtaining a bachelor’s degree. The Court explained that a Ph.D., although a higher qualification, is research-oriented and does not involve traditional coursework or examinations. It added that not every degree obtained after graduation qualifies as postgraduate; the legal and academic framework in India clearly distinguishes between postgraduate degrees and research qualifications. Consequently, the Court concluded that Dr. Deopujari’s Ph.D., obtained without holding a master’s degree, could not be considered as fulfilling the statutory requirement of Section 4(2). As a result, his appointment as Chairperson of NCISM was quashed. The fallout of this decision was immediate and impactful, as Dr. Deopujari was scheduled to retire the same week. Upon appeal to the Supreme Court, a bench led by Justice Prashant Kumar Mishra and Justice Manmohan examined the urgency and broader ramifications of the Delhi High Court ruling. The Court issued notice to the respondents and granted an interim stay on the High Court’s judgment. The primary consideration, as highlighted by the bench, was to ensure that Dr. Deopujari would not lose out on his pension and other retiral benefits because of a last-minute judgment. The Supreme Court specifically stated that it would take up for detailed consideration the legal issue of whether a Ph.D. awarded directly after graduation can satisfy the statutory condition of possessing a postgraduate qualification. Justice Mishra observed during the proceedings that this question is significant and must be examined thoroughly in the context of Indian academic standards, professional regulatory statutes, and the intent of the legislature. The stay granted by the Supreme Court does not overturn the High Court judgment but merely pauses its effect until the matter is heard in detail. This decision has temporarily safeguarded the position and benefits of Dr. Deopujari, while also keeping open the possibility of reinterpreting the law in favor of academic and experiential merit. It also underscores the tension between formal qualification frameworks and practical expertise in the governance of specialized statutory bodies. While some academic purists view the requirement of a formal postgraduate degree as non-negotiable, others advocate for a more flexible and inclusive interpretation, especially when the individual in question has demonstrated deep domain knowledge and leadership in the relevant field. This case is therefore not just about one appointment, but about how India defines and recognizes qualifications in specialized disciplines like Ayurveda, Siddha, and other Indian Systems of Medicine. With regulatory institutions like NCISM playing a critical role in standardizing education and professional practice, the outcome of this case could set a precedent for similar appointments in other commissions and councils. The final judgment by the Supreme Court will likely explore not only statutory interpretation but also comparative academic norms, the evolving nature of higher education, and the need to balance formal qualifications with practical experience. Until then, the interim stay ensures that Dr. Deopujari retains his dignity and entitlements as he demits office, while the Court deliberates on the substantive legal issues that could shape the future of professional qualifications in the regulatory framework.