Gagan Satwik v. Karnataka Examination Authority

Karnataka HC2 Sept 2025WP/24032/2025

Case brief

AI extract

What is this about?

COVID warrior quota MBBS admission 2025; extension of beneficial scheme beyond its life; policy decision exclusive domain of Executive; limited judicial review of policy; NEET-2025; deceased COVID warrior ward; Karnataka Examination Authority; Ministry of Health and Family Welfare; National Medical Commission; mandamus for representation; Anun Dhawan v Union of India 2024 SCC OnLine SC 179; writ disposed, no seat granted.

What did the court decide?

Prayer for a medical seat under the COVID warriors quota not granted; writ petition disposed of with liberty to the petitioner to make a request to the Ministry of Health and Family Welfare, Government of India, and a direction that any application already forwarded to the Ministry be disposed of expeditiously. ¶¶66

Gagan Satwik Vs Karnataka Examination Authority — Writ and Judicial Review | Karnataka HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the COVID warrior quota scheme for MBBS admissions, limited by its terms to academic sessions 2020 and 2021, should be extended by Government/judicial direction to the current year (2025) for admission of a ward of a deceased COVID warrior. +1 more

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Court's answer

This Court cannot extend the policy decision of providing reservation against five seats in Central Government Medical Colleges in All India Quota beyond the 2021 session.

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Ratio / Principle

None of the decisions of any High Court or the Supreme Court placed on record holds that a beneficial scheme can be extended by judicial intervention beyond its life.

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Key takeaways

Providing reservation to the wards of COVID warriors is a policy decision which is within the exclusive domain of the Executive.ratio¶¶56
Despite full sympathy for the petitioner who lost his doctor father during difficult times, the Court cannot formulate the policy or extend the scheme which has lived its life.ratio¶¶62
The petitioner may request the Ministry of Health and Family Welfare, Government of India for its response, and the said Ministry should take appropriate decision on such a request of the petitioner if so made.ratio

Detailed headnote1 paragraphs

Division Bench (D K Singh, J., author; Venkatesh Naik T, J.) disposed of a writ petition under Articles 226 and 227 by a petitioner, son of a doctor who died on 26.08.2020 after contracting COVID while on duty, who sought consideration for an MBBS seat under the COVID warriors quota for 2025 despite having appeared in NEET-2025 without securing a Government seat. The Court recorded that the Ministry of Health and Family Welfare scheme earmarking seats for wards of COVID warriors was confined to academic sessions 2020 and 2021 and had come to an end; that none of the cited decisions holds that a beneficial scheme can be judicially extended beyond its life; and that reservation for COVID warriors' wards is a policy matter within the exclusive domain of the Executive, which the Court cannot extend beyond the 2021 session. Relying on Anun Dhawan v. Union of India, 2024 SCC OnLine SC 179, on the limited scope of judicial review of policy, the Court expressed sympathy but declined to extend or formulate the scheme, disposed of the petition, permitted the petitioner to seek a response from the Ministry of Health and Family Welfare (which should decide appropriately), and directed expeditious disposal of any application already forwarded to that Ministry.

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NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2^ND DAY OF SEPTEMBER, 2025

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PRESENT

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THE HON'BLE MR. JUSTICE D K SINGH

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AND

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THE HON'BLE MR. JUSTICE VENKATESH NAIK T

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WRIT PETITION NO. 24032 OF 2025 (EDN-RES)

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BETWEEN:

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GAGAN SATWIK

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AGED 18 YEARS S/O LATE DR S T MANJUNATH R/AT NO. NO.51/2, SARAKKI 1 CROSS, 13TH MAIN, SARAKKI GATE, ANJANEYA TEMPLE STREET KANAKAPURA MAIN ROAD JP NAGAR I PHASE BENGALURU-560078 REPRESENTED BY MOTHER AND BEST FRIEND SMT SHYLAJA S

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Digitally signed by VASANTHA KUMARY B K Location: HIGH COURT OF KARNATAKA

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(BY SRI. MONESH KUMAR K B., ADVOCATE)

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AND:

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KARNATAKA EXAMINATION AUTHORITY 18TH CROSS ROAD, SAMPIGE RD, MALLESHWARAM, BENGALURU-560012

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…PETITIONER

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THE DIRECTOR OF MEDICAL EDUCATION BMC & RI (OLD BUILDING) I FLOOR, FORT, K R ROAD BENGALURU-560002

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THE SECRETARY HEALTH & FAMILY WELFARE DEPARTMENT VIKAS SOUDHA, BENGALURU-560001

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NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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THE DIRECTORATE GENERAL OF HEALTH SERVICES NIRMAN BHAVAN, NEW DELHI-110108

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THE UNDER SECRETARY UNDER GRADUATE MEDICAL EDUCATION BOARD NATIONAL MEDICAL COMMISSION POCKET-14, SECTOR -8 DWARKA PHASE-1, NEW DELHI-110077

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THE SECRETARY/DDG(ME), MEDICAL COUNSELLING COMMITTEE, MCC OF DGHA, NIRMAN BHAWAN NEW DELHI-110011

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…RESPONDENTS

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(BY SRI. N.K.RAMESH, ADVOCATE FOR R-1; SRI. SUDEV HEGDE, AGA FOR R-2 & R-3; SRI. SHANTHI BHUSHAN H, DSGI FOR R-4 & R-6 (MA NOT FILED) SRI. N.KHETTY, ADVOCATE FOR R-5 (VK NOT FILED))

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THIS WRIT PETITION IS UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, FILED PRAYING TO ISSUE A WRIT ORDER OR DIRECTION IN THE NATURE OF MANDAMUS TO THE RESPONDENTS TO CONSIDER THE REPRESENTATION SUBMITTED BY THE PETITIONER AND ACT UPON THE SAME AS SOUGHT IN THEIR REPRESENTATION DATED 06.06.2025 AND 11.08.2025 AND GRANT A MEDICAL SEAT UNDER THE DECEASED COVID WARRIOURS SCHEME PRODUCED AS ANNEXURE-N AND ANNEXURE-N1, ETC.

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THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

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CORAM: HON'BLE MR. JUSTICE D K SINGH and HON'BLE MR. JUSTICE VENKATESH NAIK T

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NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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ORAL ORDER

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(PER: HON'BLE MR. JUSTICE D K SINGH)

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The petitioner has appeared for NEET - 2025 for

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admission in MBBS Course. The petitioner could not secure a Government seat as per his ranking in NEET - 2025 results.

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The petitioner's father while on duty was infected by COVID virus and died on 26.08.2020. The petitioner claims that his case for admission should be considered against the four seats earmarked for the wards of COVID warriors in four named Government Medical Colleges under the scheme established by the Ministry of Health and Family Welfare.

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The fifth Government Medical College is a Girl's Medical college where one seat was reserved for the wards of the COVID warriors for the year 2020-21.

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Learned counsel for the petitioner submits that

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the COVID warrior quota scheme being a beneficial

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NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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scheme should be extended to the wards of COVID warriors, the scheme should not be limited only for two years i.e, 2020 and 2021. The Government should be directed to extend the said scheme even for the current year i.e., 2025.

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On 28.08.2025, this Court passed the following

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order:

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"Sri Shanti Bhushan, learned Deputy Solicitor General of India has brought on record the written instructions received by him in respect of the COVID-Warrior Quota scheme established by the Ministry of Health and Family Welfare for granting admission to the wards of the Covid warriors against five MBBS seats in five Central Government Medical Colleges for academic session 2020 and 2021. The instructions categorically provide that the said scheme was available only for two academic sessions i.e., 2020 and 2021, and thereafter, the said scheme has not been extended, and it has come to an end.

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The learned counsel for the petitioner submits that he would make an endeavor to cite a few judgments wherein it has been held

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5 - NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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that by judicial intervention a beneficiary scheme can be extended beyond its life.

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At the request of the learned counsel for the petitioner, post this writ petition on 01.09.2025. "

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Learned counsel for the petitioner has placed reliance on some judgments, however, none of the decisions of any of the High Court or the Supreme Court holds that a beneficial scheme can be extended by judicial intervention beyond its life.

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Providing reservation to the wards of COVID

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warriors is a policy decision which is within the exclusive domain of the Executive. Once it is affirmed that the said

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policy decision was limited only for two years i.e, 2020 and 2021, we cannot extend the said policy decision of providing reservation against five seats in Central Government Medical Colleges in All India Quota after 2021 session.

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6 - NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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We may also extract the observation of the Supreme Court in the case of Anun Dhawan and Others Vs. Union of India and others reported in 2024 SCC OnLine Sc 179 which aptly apply to the facts of the present case.

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" 8. It is well settled that the scope of judicial review in examining the policy matters is very limited. The Courts do not and cannot examine the correctness, suitability or appropriateness of a policy, nor are the courts advisors to the executive on the matters of policy which the executive is entitled to formulate. The Courts cannot direct the States to implement a particular policy or scheme on the ground that a better, fairer or wiser alternative is available. Legality of the policy, and not the wisdom or soundness of the policy, would be the subject of judicial review."

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We may have to say that we have full sympathy for the petitioner who lost his father who was working as Doctor during difficult times, but we cannot formulate the policy or extend the scheme which has lived its life. The petitioner may however request the Ministry of Health and

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7 - NC: 2025:KHC:34553-DB WP No. 24032 of 2025

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HC-KAR

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Family Welfare, Government of India for its response and the said Ministry should take appropriate decision on such a request of the petitioner if so made.

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With the above observation, we dispose of the

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writ petition. If any application is submitted before the Central Medical Education Board/National Medical Commission and if such an application is already forwarded to the Ministry of Health and Family Welfare, Government of India, same should be disposed of expeditiously.

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SD/(D K SINGH) JUDGE

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SD/(VENKATESH NAIK T) JUDGE

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RKA List No.: 1 Sl No.: 13

Gagan Satwik v. Karnataka Examination Authority

Case brief

What is this about?

What did the court decide?

Gagan Satwik v. Karnataka Examination Authority

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Cases cited

Statutes considered

Procedural history

Parties & counsel

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