Introduction:

The decision in Dr Ajay Mandloi v. Dr Aruna Kumar [CONC-1497-2026] reflects the judiciary’s firm stance against administrative high-handedness that causes undue hardship to young professionals. The order was delivered by the Madhya Pradesh High Court through Justice Jai Kumar Pillai, who directed the Director of Medical Education to return the original documents of a postgraduate medical candidate who had discontinued his course midway. The petitioner, Dr Ajay Mandloi, an MBBS graduate belonging to the Scheduled Tribe category, had appeared in NEET PG 2020 and secured an All India Rank of 79,171. He was allotted a seat in a Government Medical College during the second round of counselling and joined the postgraduate programme in July 2020. However, due to alleged ragging, nepotism and favouritism, he discontinued the course. After his exit, the college retained his original documents and demanded Rs 30 lakhs under the State’s seat bond policy. The matter assumed urgency when the petitioner qualified for the post of Medical Officer pursuant to an advertisement dated August 8, 2024, issued by the Madhya Pradesh Public Service Commission. Having received acknowledgment on January 20, 2026, he was required to submit his documents before February 23, 2026 and appear for an interview on March 5, 2026. Despite an interim direction of the High Court ordering release of his original documents, the authorities allegedly failed to comply, compelling the petitioner to initiate contempt proceedings. The High Court, expressing displeasure over the technical resistance of the authorities, directed that the documents be returned by March 2, 2026, failing which further contempt action would ensue. The matter was posted for March 9, 2026.

Arguments of the Petitioner:

The petitioner’s case was rooted in both legal principle and practical urgency. Through Senior Advocate Aditya Sanghi and Advocate Kamal Tiwari, it was contended that the retention of original educational documents was arbitrary, oppressive and violative of his fundamental rights. The petitioner submitted that although he had discontinued the postgraduate course, the authorities could not indefinitely withhold his original certificates as leverage for enforcing the bond amount of Rs 30 lakhs. It was argued that such retention amounted to coercion and effectively blocked his career progression. The petitioner highlighted that several postgraduate seats in medical colleges often remain vacant, and therefore the insistence on a disproportionately high bond amount, especially in the context of evolving national policy, was unjustified. Reference was made to discussions held in the Lok Sabha on February 9, 2024, wherein the Ministry of Health and Family Welfare indicated that the National Medical Commission had advised States to reconsider stringent bond conditions. This, according to the petitioner, reflected a broader policy shift acknowledging the hardships imposed by rigid bond regimes. More importantly, the petitioner emphasized the immediacy of the situation: he had successfully qualified for the Medical Officer position under the MP Public Service Commission advertisement and was required to submit his original documents within a stipulated deadline. Non-availability of his documents would not only deprive him of the opportunity to serve in public healthcare but would also permanently prejudice his professional future. The petitioner further argued that the High Court had already granted interim relief directing release of documents, and non-compliance with that order constituted wilful disobedience, justifying contempt proceedings. He maintained that the authorities’ insistence on procedural technicalities, despite clear judicial directions, amounted to harassment and abuse of power.

Arguments of the Respondents:

The State, represented by Advocate Sudeep Bhargava, sought to justify its position by referring to the prevailing bond policy governing postgraduate medical admissions under the State quota. It was contended that candidates who secure seats under subsidised government schemes undertake contractual obligations, including service bonds or payment of specified sums in the event of discontinuation. The retention of documents, according to the respondents, was part of the administrative process to ensure compliance with bond conditions. The authorities maintained that the petitioner had voluntarily accepted the seat and the attendant bond terms at the time of admission, and therefore could not unilaterally evade those obligations after discontinuing the course. While the respondents did not deny possession of the original documents, they appeared to rely on procedural requirements and internal administrative approvals that allegedly delayed compliance with the Court’s interim order. It was suggested that the matter involved technical formalities and coordination between departments, which may have contributed to the delay. However, the State stopped short of denying the binding nature of the Court’s direction and did not assert any legal right to permanently withhold the documents. Instead, the defence appeared to hinge on procedural justifications rather than substantive entitlement.

Court’s Judgment:

Justice Jai Kumar Pillai approached the matter with clarity and firmness. At the outset, the Court observed that it was undisputed that the original documents were in the possession of the Director of Medical Education. Once the High Court had granted interim relief directing their return, the authorities were duty-bound to comply promptly. The Court categorically stated that the petitioner could not be harassed or subjected to hardship due to “simple technicalities” when the documents were admittedly in the respondents’ custody. The Bench underscored that administrative authorities must act with fairness and reasonableness, particularly when dealing with young professionals whose careers hinge upon timely access to essential documents. The Court recognized the urgency created by the MP Public Service Commission recruitment schedule and noted that failure to return the certificates could irreparably harm the petitioner’s prospects. In unequivocal terms, Justice Pillai directed the Director of Medical Education—who was arrayed as contemnor in the contempt petition—to return the original documents by March 2, 2026, warning that failure to do so would invite further contempt proceedings. The Court’s reasoning reflects a broader constitutional ethos: while bond policies may be enforceable through lawful means, they cannot justify arbitrary retention of personal documents in defiance of judicial orders. By emphasizing that compliance with court directions is non-negotiable, the judgment reinforces the sanctity of judicial authority and the principle that administrative convenience cannot override individual rights. The case was scheduled for further hearing on March 9, 2026, thereby keeping the door open for appropriate action should non-compliance persist.