Dr. C Anusha Vs Nation National Board of… — Writ and Judicial Review | Karnataka HC (2025)

Dr. C Anusha Vs Nation National Board of… — Writ and Judicial Review | Karnataka HC (2025)

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the petitioner, having applied to NEET-PG 2025 as a General Merit candidate and having failed to use the correction window, may be permitted after declaration of the result to amend her category to Other Backward Classes (Nekar community) and have the NEET-PG 2025 merit reworked.

Court's answer

Once a candidate has filled up the NEET-UG/PG application form under a particular category and fails to correct it during the period provided for correction, the candidate, after declaration of the result, is not entitled to change the category.

Ratio / Principle

The two Karnataka High Court judgments relied on by the petitioner (Dr. Lakshmi P. Gowda and Bhanusri S.) are distinguishable on the facts, as in those cases corrections were made before the result was announced whereas here the petitioner approached the Court after the NEET-PG 2025 result was announced.

Detailed headnote1 paragraphs

Writ petition under Articles 226 and 227 of the Constitution by a NEET-PG 2025 candidate (Application ID PG25035741, Roll No. 25661038898) seeking permission to amend her category from General Merit to Other Backward Classes (Nekar community) and a consequential direction to consider her as OBC. The application deadline was 07.03.2025 with a correction window from 09.03.2025 to 11.03.2025, which the petitioner did not avail; the result was declared on 19.08.2025 and the writ petition was filed on 08.09.2025. HELD: where a candidate fills up the NEET-UG/PG form under a particular category and fails to correct it during the period provided for correction, the candidate is not entitled to change the category after declaration of the result. The Karnataka High Court decisions in Dr. Lakshmi P. Gowda (W.P. No. 12859/2023, decided 10.08.2023) and Bhanusri S. (W.P. No. 15418/2024, decided 11.07.2024) were distinguished, corrections in those cases having been made before announcement of the result. Reference was made to the Madras High Court's rejection of a similar post-result change-of-category prayer in Minor S. Jeyathinathan (W.P.M.D. No. 13687/2024), against which the Supreme Court dismissed SLP No. 18211/2024 by order dated 20.08.2024. Writ petition dismissed without costs.

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU

R

DATED THIS THE 22^ND DAY OF SEPTEMBER, 2025

PRESENT

THE HON'BLE MR. JUSTICE D K SINGH

AND

THE HON'BLE MR. JUSTICE VENKATESH NAIK T WRIT PETITION NO. 27597 OF 2025 (EDN-RES)

BETWEEN:

DR. C.ANUSHA, DAUGHTER OF C.MALLIKARJUNA, AGED ABOUT 24 YEARS, RESIDING AT HOUSE NO. 32-A, WARD NO.18, PARVATHI NAGAR, BELLARY GANDHINAGAR, SIRUGUPPA, BELLARY, KARNATAKA - 583103.

…PETITIONER

(BY SRI. VINAY KUTTAPPA K.S., ADVOCATE)

AND:

Digitally signed by DHAKSHAYINI R Location: HIGH COURT OF KARNATAKA

NATION NATIONAL BOARD OF EXAMINATIONS IN MEDICAL SCIENCES, MAHATMA GANDHI MARG (RING ROAD), ANSARI NAGAR, NEW DELHI-110029.

KARNATAKA EXAMINATION AUTHORITY, REPRESENTED BY ITS EXECUTIVE DIRECTOR, SAMPIGE ROAD, 18^TH CROSS, MALLESHWARAM, BENGALURU - 560012.

MEDICAL COUNSELING COMMITTEE (MCC), NIRMAN BHAWAN, RAJPATH AREA, CENTRAL SECRETARIAT, NEW DELHI - 110001.

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THE STATE OF KARNATAKA, DEPARTMENT OF HIGHER EDUCATION, VIDHANA SOUDHA, BENGALURU - 560001, REPRESENTED BY ITS SECRETARY.

…RESPONDENTS

(BY SRI. SHANTHI BHUSHAN H., DSGI FOR R1 AND R3; SRI. N.K.RAMESH, ADVOCATE FOR R2; SRI. SUDEV HEGDE, AGA FOR R4)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO PERMIT THE PETITIONER TO AMEND/MODIFY HER CATEGORY AS OTHER BACKWARD CLASSES (OBC) IN THE NATIONAL ELIGIBILITY-CUM-ENTRANCE TEST - PG (NEET-PG 2025) APPLICATION (APPLICATION ID PG25035741, ROLL NO. 25661038898) AND CONSEQUENTLY DIRECT THE RESPONDENTS TO CONSIDER THE PETITIONER AS BELONGING TO THE NEKAR COMMUNITY UNDER THE OTHER BACKWARD CLASSES (OBC) CATEGORY AND ETC. THIS WRIT PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE D K SINGH

AND

HON'BLE MR. JUSTICE VENKATESH NAIK T

ORAL ORDER

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

The petitioner appeared in NEET-PG 2025 for taking

admission in Post Graduate medical courses after having completed the MBBS degree. The last date for submission

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of the application form for NEET-PG 2025 was 07.03.2025.

Three days were provided for correction in the form i.e., from 09.03.2025 to 11.03.2025.

The petitioner applied as General Merit candidate in

his application to participate in the NEET-PG 2025. The result of examination of NEET-PG 2025 was declared on 19.08.2025. After the declaration of the result, the petitioner has filed this writ petition on 08.09.2025 seeking the following prayers:

"a) To permit the Petitioner to amend/modify her category as Other Backward Classes (OBC) in the National Eligibility-cum-Entrance Test - PG (NEET-PG 2025) application (Application ID PG25035741 , Roll No. 25661038898 ) and consequently direct the Respondents to consider the Petitioner as belonging to the Nekar Community under the Other Backward Classes (OBC) category; and

b) Pass such other suitable orders as this Hon'ble court deems fit to grant in the facts and circumstances of the case in the interest of justice and equity."

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In sum and substance, now the petitioner want that this Court should issue a writ of mandamus commanding the respondent - Authorities to change her category from General Merit candidate to OBC candidate and rework the merit of the result of NEET-PG 2025.

The learned counsel for the petitioner has placed reliance on two judgments of this Court - 1) Dr.Lakshmi P.Gowda vs. National Board of Examinations in Medical Sciences in W.P.No.12859/2023 dated 10.08.2023 and 2) Bhanusri.S vs. The State of Karnataka, Department of Education in W.P.No.15418/2024 dated 11.07.2024.

On the other hand, Sri Shanthi Bhushan, learned Deputy Solicitor General appearing for respondent Nos.1 and 3, Sri Sudev Hegde, learned AGA for respondent No.4 and Sri N.K.Ramesh, learned counsel for respondent No.2 would submit that the petitioner had a window to correct her application form if she was of the opinion that she

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belonged to OBC category as the bulletin of information itself provided 09.03.2025 to 11.03.2025 as the date during which a candidate would have corrected the application if some mistake was committed in filling the form. The petitioner did not choose to correct her category

and participated in the examination as a general merit category candidate. Now, the petitioner wants to change her category after she has not been successful in the NEET-PG 2025 examination. Such a course is not open otherwise it would upset the entire result of the NEET-PG 2025.

It has been further submitted that Madras High Court in the case of Minor S. Jeyathinathan vs. The National Testing Agency and Others in

W.P.M.D.No.13687/2024 had rejected such a prayer of the candidate for change of category after the result was announced and the Supreme Court has dismissed the Special Leave Petition against the said judgment being SLP.No.18211/2024 vide the order dated 20.08.2024.

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We have considered the two judgments of this Court cited by the learned counsel for the petitioner. In the case of Dr. Lakshmi P. Gowda (supra), this Court has specifically held that the judgment shall not be treated as precedent in future and in the case of Bhanusri S. (supra), this Court has held that permitting the petitioner in that case to her correct category in the application as Other Backward Classes category would neither prejudice other students nor entitle the petitioner to reap the benefit. In that case, the application was made for corrections before the result was announced. Here, the petitioner has come before this Court after the result of NEET-PG 2025 was announced. Therefore, both the cases relied on by the learned counsel for the petitioner are distinguishable on the facts of the present case.

The hold that once, a candidate has filled up his/her form for NEET-UG/PG belonging to a particular category and if he/she fails to correct the application form during the period provided for correction by the National Testing

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Agency, a candidate, after declaration of the result would

not be entitled to change his/her category.

We, therefore, find no substance in this writ petition. Accordingly, the writ petition is hereby dismissed, however without costs.

SD/(D K SINGH) JUDGE

SD/(VENKATESH NAIK T) JUDGE

DHA

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