Introduction:
The Supreme Court, in the case of Anmol v. Union of India & Ors (Civil Appeal No. 14333 of 2024), delivered a landmark ruling on February 21, 2025, striking down the National Medical Commission’s (NMC) eligibility criterion that required MBBS aspirants with disabilities to have “both hands intact, with intact sensation and sufficient strength.” The bench, comprising Justice BR Gavai and Justice KV Viswanathan, held that this requirement was arbitrary, unconstitutional, and violative of the Rights of Persons with Disabilities (RPwD) Act, 2016. The Court directed the admission of the petitioner, Anmol, to the MBBS course at Government Medical College, Sirohi, Rajasthan. Justice Viswanathan, authoring the judgment, emphasized that the requirement glorified ableism and failed to recognize the principles of reasonable accommodation under the Constitution and the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). The ruling also flagged the NMC’s failure to revise its guidelines despite multiple directives in previous judgments, including Omkar Ramchandra Gond v. Union of India and Om Rathod v. Director General of Health Services & Ors.
Arguments of Both Sides:
The petitioner, Anmol, challenged the NMC’s guidelines, arguing that they imposed an overbroad and discriminatory classification that violated Article 41 of the Constitution, the RPwD Act, and international conventions. Anmol, who suffered from a locomotor disability (50%) and additional speech and language disabilities (20%), had been declared ineligible for MBBS admission by an Assessment Board on September 2, 2024. The petitioner contended that the assessment failed to consider functional abilities and reasonable accommodations, unfairly disqualifying him based solely on physical criteria rather than an individualized evaluation of his competency to pursue medical education. The petitioner relied on Supreme Court precedents in Omkar Ramchandra Gond and Om Rathod, which held that functional assessments, rather than arbitrary physical standards, should determine eligibility for MBBS admissions.
The Union of India and NMC defended the regulation, asserting that medical training, particularly in surgical fields, required full motor functionality of both hands. They contended that the regulation was designed to ensure patient safety and uphold professional medical standards. They also argued that the guidelines had been framed after expert consultation and were necessary to maintain quality in medical education. However, they failed to substantiate why an individualized functional assessment, as prescribed in previous judgments, was not incorporated into the evaluation process.
Court’s Judgment:
The Supreme Court rejected the NMC’s argument, holding that the “both hands intact” criterion was not only unconstitutional but also a blatant manifestation of ableism. The Court stressed that the RPwD Act mandates reasonable accommodation, which the impugned guideline completely disregarded. Justice Viswanathan observed that a rigid, blanket criterion without individualized functional assessment violated Article 41 of the Constitution, which ensures the right to education and employment for persons with disabilities. The Court noted that functional competency should be assessed based on the ability to perform essential tasks with or without assistive devices, rather than an arbitrary requirement of “intact hands.”
The Court also examined the AIIMS Doctor’s Committee report, which had been constituted per its directive. The report, however, failed to justify Anmol’s disqualification, as it did not engage in a functional assessment of his abilities but merely reiterated the existing NMC guidelines. The Court criticized this approach, stating that it ran contrary to the principles laid down in Omkar Ramchandra Gond and Om Rathod, where the Court had mandated a qualitative rather than a quantitative approach to disability assessment.
Further, the Court pointed out that in Omkar Ramchandra Gond, it had directed the NMC to revise its guidelines to align with international disability rights standards. Similarly, in Om Rathod, the Court had explicitly rejected the “both hands intact” requirement. Despite these clear directives, the NMC had failed to update its regulations, prompting the Court to order an urgent reassessment of the policy. The Court reiterated that rejecting candidates at the threshold due to arbitrary physical criteria, without considering their ability to function with accommodations, amounted to systemic discrimination against persons with disabilities.
The Supreme Court also relied on the expert opinion of Professor Dr Satendra Singh, a disability rights advocate and medical professional, who opined that candidates should be allowed to complete the MBBS course and then decide whether they wish to specialize in a non-surgical or medical branch. The Court endorsed this approach, stating that barring a candidate at the admission stage without exploring potential accommodations and assistive technologies was unfair and unconstitutional.
Concluding its judgment, the Court allowed Anmol’s appeal and directed his immediate admission to the MBBS course at Government Medical College, Sirohi. Additionally, it scheduled a hearing on March 3, 2025, to assess whether the NMC had formulated revised guidelines in compliance with the Court’s directives in Omkar Ramchandra Gond and Om Rathod. The Court directed the NMC to file an affidavit detailing the status of its compliance before the next hearing date.