Dismissed¶155

Dr.Navin Nayan v. the State of Tamilnadu

Madras HC15 Sept 2025WP/18176/2025

Case brief

AI extract

What is this about?

Compulsory bond — Non Service Post Graduates (Super Specialty) — 2025 completion batch — writ of mandamus under Article 226 to confer benefit of G.O.Ms.No.49 Health and Family Welfare (MCA-1) Department dated 28.02.2024 — reduction of bond period from two years to one year and bond amount from Rs.50,00,000/- to Rs.25,00,000/- — G.O.Ms.No.351 dated 27.10.2023 — amendment by G.O.Ms.No.121 dated 31.05.2024 — benefit confined to candidates who completed Post Graduate course in academic year 2023 — Tamil Nadu Government Medical Colleges — writ petition dismissed, no costs.

What did the court decide?

None; the writ petition was dismissed, the connected miscellaneous petition was closed, and there shall be no order as to costs. ¶155

Dr.Navin Nayan Vs the State of Tamilnadu — Writ and Judicial Review | Madras HC (2025)

What the court decided

AI extract

Outcome

None; the writ petition was dismissed, the connected miscellaneous petition was closed, and there shall be no order as to costs.

¶155

Issue for consideration

Whether the petitioners, Non-Service Post Graduates (Super Specialty) who completed their course in the year 2025, are entitled to the benefit of G.O.Ms.No.49, Health and Family Welfare (MCA-1) Department, dated 28.02.2024, i.e., reduction of the compulsory bond service from two years to one year and the bond amount from Rs.50,00,000/- to Rs.25,00,000/-.

¶100

Court's answer

Only candidates who completed their Post Graduate course during the academic year 2023 in the Tamil Nadu Government Medical Colleges are entitled to the benefit of reduction of the bond period from two years to one year and the bond amount from Rs.50,00,000/- to Rs.25,00,000/-.

¶147

Ratio / Principle

All the petitioners completed their Post Graduate (Super Specialty) Degree as Non-Service candidates in the year 2025.

¶150

Key takeaways

The petitioners are not entitled to the benefits conferred under G.O.Ms.No.49, Health and Family Welfare (MCA-1) Department, dated 28.02.2024; the writ petition is devoid of merits and liable to be dismissed.ratio¶154

Detailed headnote1 paragraphs

Writ petition under Article 226 of the Constitution of India by 85 Non-Service Post Graduates (Super Specialty) who joined the 5th to 15th respondent Government Medical Colleges in 2022 and completed their course in 2025, seeking conferment of the benefit of G.O.Ms.No.49, Health and Family Welfare (MCA-1) Department, dated 28.02.2024, namely reduction of the compulsory bond service from two years to one year and the bond amount from Rs.50,00,000/- to Rs.25,00,000/-. Held, dismissing the petition: reading G.O.Ms.No.351 dated 27.10.2023, G.O.Ms.No.49 dated 28.02.2024 and its amendment in G.O.Ms.No.121 dated 31.05.2024 together, only candidates who completed their Post Graduate courses during the academic year 2023 are entitled to the reduction of bond period and bond amount; the petitioners, having completed in 2025 as Non-Service candidates, are not entitled to the benefit. Connected miscellaneous petition closed; no order as to costs.

¶1

W.P.No.18176 of 2025

¶2

IN THE HIGH COURT OF JUDICATURE AT MADRAS

¶3

DATED : 15.09.2025

¶4

CORAM

¶5

THE HONOURABLE MR.JUSTICE G.K.ILANTHIRAIYAN

¶6

W.P.No.18176 of 2025

¶7

and

¶8

W.M.P.No.20358 of 2025

¶9

1.Dr.Navin Nayan

¶10

2.Dr. Ranjeet Ram Jat

¶11

3.Dr. Ruhi Kumar

¶12

4.Dr. Onkar Singh Matharu

¶13

5.Dr. Rajesh B S

¶14

6.Dr. Saifi Rana

¶15

7.Dr. Harrini Devi

¶16

8.Dr. Surabhi

¶17

9.Dr. Mohanraj P

¶18

10.Dr. Rinesh Kochummen

¶19

11.Dr. Agera Stefan Valerian

¶20

12.Dr. Kondle Venkatesh

¶21

13.Dr. Biju Azariah

¶22

14.Dr. Sreenath G Nair

¶23

15.Dr. Sathish Kumar M

¶24

16.Dr. Haritha

¶25

17.Dr. Deepak Rajendran

¶26

18.Dr. Ashok Kumar B

¶27

19.Dr. Manish Kumar Sharma

¶28

Page 1 of 16

¶29

https://www.mhc.tn.gov.in/judis

¶30

W.P.No.18176 of 2025

¶31

20.Dr. V V Rohit Bhaskarla

¶32

21.Dr. Aubin Mathew Varghese

¶33

22.Dr. Tino Baby

¶34

23.Dr. Kanithi S.S.S Surya Prakash

¶35

24.Dr. Srilekha D

¶36

25.Dr. Anoop C

¶37

26.Dr. Srinivasa Rao Reddy

¶38

27.Dr. Dhivya E

¶39

28.Dr. V G Vikraman 29.Dr. V. Radha Krishna

¶40

30.Mohamed Aaseem Arshad V S, 31.Dr. Pinakin Thakorbhai Tandel 32.Dr. Hazi Zawar Sadiq Abbas,

¶41

33.Dr. Priyanka Raju 34.Dr. Hrishikesh S Pai,

¶42

35.Dr. Soumyakanti Das 36.Dr. Suyash Singodiya 37.Dr. Jagadish Kumar Chappa 38.Dr. Shaoni Parai

¶43

39.Dr. Naweed Alam, 40.Dr. Indhuja Karunakaran 41.Dr. Atul J G

¶44

42.Dr. Ronak Jain G

¶45

43.Dr. Srinidhi

¶46

44.Dr. M Vinoth 45.Aravindan S P 46.Dr. Jishnu J 47.Dr. Roopashree K R

¶47

48.Dr. Susanta Kumar Dash

¶48

49.Dr. Raja S 50.Dr. Aravind Vishweshwar Page 2 of 16

¶49

https://www.mhc.tn.gov.in/judis

¶50

W.P.No.18176 of 2025

¶51

51.Dr. Bhuvana Lakshmi 52.Harish Chandika 53.Dr. Kirthiga Thiagarajan

¶52

54.Dr. Sachin James

¶53

55.Dr. Jaison James

¶54

56.Dr. Harsh Saxena 57.Dr. V.S. Veerappan 58.Dr. Arunrajkumar P 59.Dr. Soorya Sekar 60.Dr. Sheik Khurshid Alam Ali 61.Dr. Nischal Modak

¶55

62.Dr. Ravi Vimalnath

¶56

63.Dr. Balaji Prathep S 64.V.N. Vignesh Shantham, 65.Dr. Vinodh Kumar K S 66.Dr. Karthikai Selvi D

¶57

67.Dr. Senthilnathan

¶58

68.Dr. Harish M 69.Dr. Vaisagh Remin

¶59

70.Dr. Vandana K V

¶60

71.Dr. K.Vignesh 72.Dr. Nitin Ramesh 73.Dr. Nilesh Charawande

¶61

74.Dr. Patel Jimmykumar Mukeshkumar 75.Dr. Sanjeeva Raju Kunche 76.Dr. Gopikrishnan 77.Dr. Sindhu B R 78.Dr. Abhilash B 79.N. Jeyachandran 80.Amrita Manjusha Page 3 of 16

¶62

https://www.mhc.tn.gov.in/judis

¶63

W.P.No.18176 of 2025

¶64

81.Bharath Kumar Reddy 82.Dr. R.S. Manikandan 83.Dr. Aditya Sivaram S 84.Dr. Srinathh Sarma S V 85.Dr. P. Nivethaa

¶65

..... Petitioners

¶66

¶67

1.The State of Tamil Nadu, Represented by its Principal Secretary, Health and Family Department, Secretariat, Chennai 600 009.

¶68

2.Directorate of Medical Education, Represented by the Deputy Director of Medical Education, Kilpauk, Chennai 600 010.

¶69

The Director of Medical and Rural Health Services, Anna Salai, Chennai-600006

¶70

The Directorate of Public Health and Preventive Medicine Anna Salai, Teynampet, Chennai 600086

¶71

Madras Medical College, Represented by its Dean, E.V.R. Salai, Chennai 600 003.

¶72

Government Kilpauk Medical College, Represented by its Dean, Page 4 of 16

¶73

https://www.mhc.tn.gov.in/judis

¶74

W.P.No.18176 of 2025

¶75

Poonamalee High Road, Kilpauk, Chennai 600 010.

¶76

Government Chengalpattu Medical College, Represented by its Dean, G.S.T. Road, Chengalpattu District, Kancheepuram 603 001.

¶77

Kanyakumari Government Medical College, Represented by its Dean, Asaripallam, Nagercoil, Kanayakumari District, Tamil Nadu 629 201.

¶78

Thanjavur Medical College, Represented by its Dean, Thanjavur 613 004.

¶79

Stanley Medical College Represented by its Dean, No.1 Old Jail Road, Chennai 600 001.

¶80

Government Mohan Kumaramangalam Medical College Hospital Represented by its Dean, Fort Main Road, Salem 636 002.

¶81

Coimbatore Government Medical College, Represented by its Dean, Page 5 of 16

¶82

https://www.mhc.tn.gov.in/judis

¶83

W.P.No.18176 of 2025

¶84

Coimbatore 641 018.

¶85

Tirunelveli Medical College, Represented by its Dean, High Ground Road, Palayamkottai, Tirunelveli 627 011.

¶86

Madurai Medical College, Represented by its Dean, Panagal Road, Alwarpuram, Madurai 625 050.

¶87

Thoothukudi Government Medical College and Hospital, Represented by its Dean, Kamaraj Nagar, Thoothukudi, Tamil Nadu 628 008. ..... Respondents Prayer:- Writ Petition filed under Article 226 of Constitution of India for

¶88

the issuance of Writ of Mandamus, directing the respondents to confer the

¶89

benefit of G.O.Ms.No.49 Health and Family Welfare (MCA-1) Department dated 28.02.2024 to the petitioners herein who are Non Service Post Graduates (Super Specialty) who completed their course in the year 2025 and reduce the compulsory bond service of the petitioners from two years to one year and reduce the bond amount from Rs.50,00,000/- to Rs.25,00,000/-.

¶90

For Petitioner : Mr.C.Vidhusan For Respondents : Mr.K.Tippu Sulthan

¶91

Page 6 of 16

¶92

https://www.mhc.tn.gov.in/judis

Government Advocate

ORDER

W.P.No.18176 of 2025

This Writ Petition has been filed seeking a direction to the

¶97

respondents to confer the benefit of G.O.Ms.No.49, Health and Family

¶98

Welfare (MCA-1) Department, dated 28.02.2024, to the petitioners

¶99

herein, who are Non-service Post Graduates (Super Specialty), who have

¶100

completed their course in the year 2025, and consequently to reduce the compulsory bond service from two years to one year and the bond

¶101

amount from Rs.50,00,000/- to Rs.25,00,000/-.

¶102

2. Heard the learned counsel appearing on either side and

¶103

perused the materials available on record.

¶104

3. The petitioners had joined the Post Graduate Super

¶105

th th Specialty Degree Course in the 5 to 15 respondent Colleges during the

¶106

year 2022 and completed the said course in the year 2025. In the

¶107

meanwhile, the first respondent issued G.O.Ms.No.351, Health and

¶108

Family Welfare (MCA-1) Department, dated 27.10.2023, thereby ordered

¶109

Page 7 of 16

¶110

https://www.mhc.tn.gov.in/judis

¶111

W.P.No.18176 of 2025

¶112

as follows :

¶113

“6. The Government, hereby issues the following

¶114

orders regarding the implementation of the bond requirement for Non Service Post Graduates to Post Graduate Degree/Diploma Courses in Tamil Nadu Government Medical Colleges after carefully reviewing the request of the Director of Medical Education and Research and the suggestions made by the committee members :-

¶115

i. The bond period for Non Service Post Graduates (Degree/Diploma) who have completed their Post Graduate courses in the year 2023 will be reduced from tow years to one year (from the date of joining in the bond service) and the respective prospectus for the Post Graduate Degree course for the academic year 20202021 as well as for the Diploma course for the academic year 2021-2022 will be amended accordingly.

¶116

ii. The bond amount for the Non Service Post Graduates who have completed their Post Graduate

¶117

Page 8 of 16

¶118

https://www.mhc.tn.gov.in/judis

¶119

W.P.No.18176 of 2025 Degree curses in 2023 will be Rs.20,00,000/- only (Twnety lakhs) instead of Rs.40,00,000/- (Forty lakhs) and for the Non Service Post Graduates who have completed their Post Graduate Diploma courses in 2023 will be Rs.10,00,000/- only (Ten lakhs) instead of Rs.20,00,000/(Twenty lakhs)

¶120

iii. Depending on the need and availability of vacancies in the future, the Health Department henceforth will review and consider the enforcement of 2 years bond condition every year and issue necessary directions for utilizing the services of the Non-service Post Graduates in Tamil Nadu Medical Services and issue appropriate orders.”

¶121

4. Thereafter, the first respondent issued G.O.Ms.No.49,

¶122

Health and Family Welfare (MCA-1) Department, dated 28.02.2024, wherein the following orders were passed :-

¶123

“4. The Government after careful examination have

¶124

proposed to accept the request of the Director of Medical Page 9 of 16

¶125

https://www.mhc.tn.gov.in/judis

¶126

W.P.No.18176 of 2025 Education and Research and decided to issue the following orders :-

¶127

i. The bond amount for Non Service Post Graduates

¶128

(PG Dental) who have completed their Post Graduate Course in the year 2023 onwards will be Rs.20,00,000/(Rupees Twenty Lakh only) instead of Rs.40,00,000/(Rupees Forty lakhs).

¶129

ii. The bond amount for Non Service Post Graduates (Super Specialty) who have completed their Post Graduate Course in the year 2023 onwards will be Rs.25,00,000/- (Rupees Twenty Five Lakh only) instead of Rs.50,00,000/- (Rupees Fifty Lakh)

¶130

iii. The bond period for Non Service Post Graduates (Dental/Super Specialty) who have completed their Post Graduate Courses in the year 2023 onwards will be reduced from two years to one year.

¶131

iv. The Prospectus of PG Dental and G.O.(Ms) No.462, Health and Family Welfare Department, dated 07.11.2020 for Super Specialty Course issued for the

¶132

academic year 2020-2021 will be amended accordingly.

¶133

v. The Services of the Non Service Post Graduates

¶134

Page 10 of 16

¶135

https://www.mhc.tn.gov.in/judis

¶136

W.P.No.18176 of 2025 (Dental/Super Specialty) Courses will be utilized on Need

¶137

Basis and as per vacancy anywhere in Tamil Nadu.”

¶138

5. Subsequently, by way of amendment, the first respondent

¶139

issued another order in G.O.Ms.No.121, Health and Family Welfare

¶140

(MCA-1) Department, dated 31.05.2024, wherein the following

¶141

amendments were made :-

¶142

“For the existing para 4(iii), the following shall be

¶143

substituted :-

¶144

“The bond period for Non Service Post Graduates (Dental/Super Specialty) who have completed their Post Graduate Courses in the year 2023 will be reduced from two years to one year”.

¶145

6. Thus, it is clear that only those candidates who had

¶146

completed their Post Graduate during the academic year 2023 under the

¶147

Tamil Nadu Government Medical Colleges are entitled to the benefit of

¶148

reduction of the bond period from two years to one year and bond amount

¶149

from Rs.50,00,000/- to Rs.25,00,000/-. Admittedly, all the petitioners

¶150

have completed their Post Graduate (Super Specialty) Degree as Non Page 11 of 16

¶151

https://www.mhc.tn.gov.in/judis

¶152

W.P.No.18176 of 2025

¶153

Service candidates in the year 2025.

¶154

7. In view of the above, the petitioners are not entitled to the

¶155

benefits conferred under G.O.Ms.No.49, Health and Family Welfare (MCA-1) Department, dated 28.02.2024. Hence, this writ petition is devoid of merits and is liable to be dismissed. Accordingly, this Writ Petition stands dismissed. Consequently, connected miscellaneous petition is closed. There shall be no order as to costs.

¶156

15.09.2025

¶157

Internet : Yes Index : Yes/No Neutral Citation : Yes/No Lpp

¶158

¶159

1.The Principal Secretary, State of Tamil Nadu Health and Family Department, Secretariat, Chennai 600 009. Page 12 of 16

¶160

https://www.mhc.tn.gov.in/judis

¶161

W.P.No.18176 of 2025

¶162