Introduction:
The Supreme Court of India, invoking its extraordinary constitutional powers under Article 142, passed a humane and far-reaching interim order to protect the educational future of a young medical aspirant belonging to the Economically Weaker Section (EWS). The case arose from a systemic vacuum in the implementation of EWS reservation in private medical colleges in the State of Madhya Pradesh, which had resulted in a meritorious candidate repeatedly qualifying the NEET examination yet being denied admission to the MBBS course.
The petitioner, Atharv Chaturvedi, appeared before the Supreme Court in person, highlighting the gravity of the situation and the personal toll caused by administrative inertia. Despite qualifying NEET twice, he could not secure admission due to the State’s failure to frame and implement a concrete policy extending EWS reservation to private medical institutions. His grievance had earlier been rejected by the Madhya Pradesh High Court, which accepted the State’s submission that EWS seats could not be granted in private colleges as the total number of seats had not been enhanced.
The matter was heard by a Bench comprising Chief Justice of India Surya Kant, Justice Joymalya Bagchi, and Justice N. V. Anjaria, who expressed deep concern over the denial of opportunity to a deserving candidate due to policy paralysis. Emphasising that constitutional guarantees cannot be rendered illusory by executive delay, the Court directed the National Medical Commission (NMC) and the State of Madhya Pradesh, through its Department of Medical Education, to ensure provisional admission of the petitioner to an MBBS course for the academic session 2025–26, strictly in accordance with his EWS rank, subject to payment of requisite fees and compliance with formalities.
Arguments on Behalf of the Petitioner:
The petitioner contended that his case was a classic example of how merit and constitutional entitlement can be defeated by administrative indecision. He submitted that he had successfully qualified the NEET examination twice, demonstrating both academic competence and perseverance, yet remained without an MBBS seat solely because the State had failed to operationalise EWS reservation in private medical colleges.
It was argued that Articles 14 and 15(6) of the Constitution, which recognise and protect EWS reservation, impose a positive obligation on the State to ensure that such reservation is meaningfully implemented and not reduced to a paper promise. The petitioner emphasised that the absence of a policy could not be used as a justification to deny him admission, particularly when similarly placed candidates from other reserved categories were benefiting from reservations in private institutions.
He further submitted that the State’s inaction had the effect of arbitrarily excluding EWS candidates from a substantial portion of available medical seats, thereby violating the principle of substantive equality. The petitioner highlighted that he had approached the authorities repeatedly and had also participated in counselling in good faith, hoping that the constitutional mandate would eventually be honoured. His participation in counselling, he argued, could not amount to acquiescence or estoppel against asserting fundamental and constitutional rights.
The petitioner also relied on the equitable jurisdiction of the Supreme Court under Article 142, urging the Court to intervene to do “complete justice” in a situation where procedural rigidity and policy delay threatened to irreversibly damage his career. He stressed that denial of admission for yet another academic year would not only waste his youth and effort but would also undermine public confidence in the fairness of the educational system.
Arguments on Behalf of the State of Madhya Pradesh and Other Respondents:
The State of Madhya Pradesh, through its counsel, submitted that the issue of extending EWS reservation to private medical colleges was under active consideration, and that the State was in the process of formulating appropriate guidelines and policy frameworks. It was contended that without a clear policy and corresponding enhancement of seats, granting EWS reservation in private institutions could lead to complications and potential exploitation of students.
The State relied heavily on the reasoning adopted by the Madhya Pradesh High Court, which had earlier declined relief on the ground that EWS seats could not be carved out unless the overall intake capacity was increased. According to the State, implementing EWS reservation in private colleges without seat enhancement might adversely affect other categories and disrupt the existing admission structure.
Another key submission advanced by the State was based on the doctrine of estoppel. It was argued that the petitioner had participated in the counselling process with full knowledge of the prevailing conditions and absence of EWS reservation in private colleges. Having voluntarily taken part in the process, the petitioner could not subsequently turn around and challenge the same framework once he failed to secure admission.
The State also expressed concern that granting relief at this stage, particularly in relation to private colleges, might result in future disputes or exploitation, especially if private institutions later questioned the applicability of reservation norms. The counsel urged the Court to exercise restraint and allow the policy-making process to reach its logical conclusion rather than issuing interim directions that could have wider ramifications.
Observations and Judgment of the Supreme Court:
The Supreme Court was unpersuaded by the submissions of the State and expressed strong disapproval of the approach adopted by the authorities. The Bench repeatedly emphasised that bureaucratic delay and policy indecision cannot be permitted to destroy the career of a young and deserving student.
The Court noted that the petitioner had qualified NEET not once but twice, and that his inability to secure admission was not due to lack of merit but due to systemic failure. Describing the petitioner as “a young boy belonging to the Economically Weaker Section,” the Court observed that it would be a travesty of justice if constitutional promises were rendered meaningless by executive inaction.
Invoking Article 142, the Court held that it was empowered to pass orders necessary to ensure complete justice, especially in cases where rigid adherence to procedure would result in manifest injustice. The Bench categorically directed the National Medical Commission and the State of Madhya Pradesh, through the Department of Medical Education, to ensure that the petitioner is provisionally admitted to an MBBS course for the 2025–26 academic session, strictly as per his EWS rank, subject to deposit of fees and completion of other formalities.
During the hearing, when the State counsel submitted that the reservation policy for private colleges was still under consideration, CJI Surya Kant made a scathing remark, stating that if private colleges refuse to follow reservation policies, “close them, put a lock on them.” This observation underscored the Court’s view that private institutions, once brought within the regulatory framework, cannot selectively ignore constitutional and statutory obligations.
When the State expressed concern about potential exploitation of the student by private colleges, the CJI responded firmly, asking the State to “bring that private college before us,” signalling the Court’s readiness to directly intervene against errant institutions. The Bench further cautioned the State against allowing procedural delays to “spoil the career of this boy,” making it clear that the student’s future could not be sacrificed at the altar of administrative convenience.
Rejecting the plea of estoppel, the Court held that participation in counselling does not bar a candidate from asserting constitutional rights, particularly when the challenge arises from a structural deficiency in policy implementation. The Court implicitly reaffirmed that equity, fairness, and justice must guide admission processes, especially in professional courses where lost time can never be recovered.