Introduction:

The Madhya Pradesh High Court in Dr Ajay Mandloi v State of MP WP 6226 of 2026 granted interim relief to a postgraduate medical student whose original academic documents had been withheld by a Government Medical College following his discontinuation of a postgraduate course. The Bench of Justice Jai Kumar Pillai directed that the petitioner’s original certificates along with an objection certificate be returned subject to the final outcome of the writ petition. The dispute arose from a ₹30 lakh seat leaving bond imposed under the State policy after the petitioner left the course. The petitioner, an MBBS graduate belonging to the Scheduled Tribe category, had secured an All India Rank of 79,171 in NEET PG 2020 and was allotted a postgraduate seat during the second round of counselling. He joined the course on July 27, 2020 but later discontinued his studies citing ragging nepotism and favouritism. Upon leaving, the college retained his original documents and demanded payment under the seat leaving bond policy. Aggrieved by the retention of certificates which he required for a recruitment process, the petitioner approached the High Court seeking urgent relief.

Arguments of the Petitioner:

The petitioner through Senior Advocate Aditya Sanghi assisted by Advocate Chetan Jain argued that the continued withholding of his original certificates was arbitrary unreasonable and violative of his fundamental rights. It was submitted that the petitioner had been compelled to leave the course due to hostile circumstances including ragging and favouritism which adversely affected his academic environment. Despite discontinuation, the college retained his original documents and demanded ₹30 lakh under the State’s seat leaving bond policy. The petitioner contended that such an exorbitant bond amount had come under national scrutiny. Reference was made to discussions 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 review such policies. The petition highlighted that over the past decade there had been a substantial increase in undergraduate and postgraduate medical seats across the country thereby reducing the justification for imposing heavy penalties on candidates who discontinue courses. It was further argued that high bond amounts cause severe financial and psychological stress particularly to candidates from marginalized backgrounds. The petitioner emphasized that vacant postgraduate seats often remain unfilled and therefore the rationale of compensating the State for financial loss is overstated. Crucially the petitioner had qualified for the post of Medical Officer pursuant to an advertisement dated August 8, 2024 issued by the Madhya Pradesh Public Service Commission. He received acknowledgement on January 20, 2026 and was scheduled to appear for interview on March 5, 2026 with mandatory document submission by February 23, 2026. The withholding of his certificates would effectively deprive him of participating in the recruitment process and cause irreparable injury to his career. It was argued that retention of original documents as a coercive mechanism to enforce bond payment lacked proportionality and fairness.

Arguments of the State:

The State represented by Government Advocate Ayushyaman Choudhary opposed the plea and submitted that the petitioner had voluntarily executed the bond agreement at the time of admission. It was argued that postgraduate medical education in Government institutions is heavily subsidized and the bond policy is intended to deter candidates from leaving seats vacant after allotment. According to the State the bond amount of ₹30 lakh was part of the regulatory framework governing admissions and candidates were fully aware of the consequences of discontinuation. The respondents contended that permitting students to exit without financial consequence would disrupt the counselling system and cause administrative and academic loss. It was further argued that the writ petition was premature and that the petitioner was obligated to comply with the bond terms before seeking equitable relief. However upon preliminary consideration the State did not dispute that the petitioner required his documents urgently for participating in the recruitment process.

Court’s Judgment:

Justice Jai Kumar Pillai after examining the submissions observed that the petitioner had made out a prima facie case warranting interim protection. The Court noted that the matter concerning validity and proportionality of seat leaving bonds required detailed adjudication and was also listed along with another similar writ petition. However the immediate concern was the imminent deadline for submission of documents in the Medical Officer recruitment process. The Court recognized that withholding original academic certificates could result in irreparable harm by foreclosing the petitioner’s employment opportunity. In order to maintain parity with a previous case relied upon by the petitioner the Bench directed respondent authorities to return the original documents along with the objection certificate upon due acknowledgement. Importantly the Court clarified that such return would remain subject to the final outcome of the writ petition thereby safeguarding the State’s interests pending adjudication. The interim order struck a balance between enforcement of contractual bond obligations and protection of the petitioner’s immediate career prospects. By issuing notice and granting time bound relief the High Court ensured that the petitioner would not be prejudiced before the legality of the bond policy is finally determined.