Dismissed¶57

Prahalad Ram v. The National Medical Commission

Madras HC26 Mar 2026WA/760/2026

Case brief

AI extract

What is this about?

Madras HC writ appeal dismissed; MBBS student discharged after four unsuccessful First Year attempts; Regulation 7.7 Regulations on Graduated Medical Education (Amendment) 2019 four-attempt cap; partial/restricted attendance counted as attempt; Sachin & Ors. vs. Union of India MANU/DE/5462/2022 (Delhi HC); challenge rejected in SLP (C) No.22716 of 2022 (SC, 10.2.2023); no relaxation provision shown; judicial deference to academic authorities; Kanyakumari Government Medical College; TN Dr.M.G.R Medical University; National Medical Commission.

What did the court decide?

When the authorities have categorically opined that the appellant had exhausted the maximum attempts permissible, the writ court cannot sit in appeal over that decision nor once again analyze whether an attempt was a restricted attempt or a regular attempt. ¶56

Prahalad Ram Vs The National Medical Commission — Madras HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether counting restricted appearances or examination sessions (in which the appellant was expressly instructed not to write certain subjects) as full attempts towards the four-attempt limit under Regulation 7.7 is irrational, illegal and contrary to established principles governing academic evaluation. +2 more

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Court's answer

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Ratio / Principle

No provision permitting relaxation of Regulation 7.7 or affording one additional chance to clear the first Professional Examination, even on sympathetic considerations, was placed on record by the appellant.

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Key takeaways

In any event, the educational authorities are the best qualified persons to assess the academic performance of a student.ratio¶56
The order of the learned Single Judge does not warrant any interference; accordingly, the writ appeal is dismissed with no order as to costs.ratio¶56

Detailed headnote1 paragraphs

Division Bench of the Madras High Court (Chief Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan) dismisses W.A.No.760 of 2026, upholding the learned Single Judge's order dated 26.02.2026 in W.P.No.47974 of 2025. The appellant, discharged and relieved by proceedings dated 6.2.2025 of the Dean, Kanyakumari Government Medical College for not clearing his First Year MBBS Examination in four attempts, had contended that restricted appearances/sessions in which he was told not to write certain subjects were wrongly counted as full attempts. The Court applies Regulation No.7.7 of the Regulations on Graduated Medical Education (Amendment), 2019 — no more than four attempts for the first Professional examination, partial attendance of examination in any subject counted as an attempt — whose validity was upheld by a Division Bench of the Delhi High Court in Sachin & Ors. vs. Union of India and Ors. (MANU/DE/5462/2022) and whose challenge was rejected by the Supreme Court vide order dated 10.2.2023 in SLP (C) No.22716 of 2022. Holding that the appellant placed no provision on record permitting relaxation or an additional chance even on sympathetic considerations, that the writ court cannot sit in appeal over the authorities' categorical opinion that the maximum attempts were exhausted, and that educational authorities are best qualified to assess academic performance, the Court finds no ground for interference and dismisses the appeal with no order as to costs.

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W.A.No.760 of 2026

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 26.03.2026

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CORAM :

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THE HONOURABLE MR. SUSHRUT ARVIND DHARMADHIKARI, CHIEF JUSTICE

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AND

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THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN

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WA No. 760 of 2026

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Prahalad Ram S/o.Vagta Ram, Residing at Govinda Gorkhede Complex, Hazaripahad, Seminary Hills, Nakpur, Maharastra - 440006.

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Appellant(s)

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The National Medical Commission Pocket 14, Sector -8, Dwarka Phase - 1, New Delhi, India - 110077.

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The Director of Medical Education Government of Tamil Nadu, DPI Complex, College Road, Chennai - 600 006.

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The Vice Chancellor Tamil Nadu Dr.M.G.R Medical University, No.69, Anna Salai, Guindy, Chennai - 600 032.

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

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W.A.No.760 of 2026

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4. The Controller of Examinations

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Tamil Nadu Dr.M.G.R Medical University, No.69, Anna Salai, Guindy, Chennai - 600 032.

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The Dean Kanyakumari Government Medical College, Asaripallam, Tamil Nadu - 629201.

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The Principal Kanyakumari Government Medical College, Asari Pallam, Tamil Nadu - 629201.

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Respondent(s)

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PRAYER: Appeal under Clause 15 of the Letters Patent To set aside the order dated 26.02.2026 passed in WP No.47974 of 2025 by allowing the present Writ Appeal and consequently direct the respondents to permit the Appellant to appear for Human Anatomy and Biochemistry in his remaining attempts and thereby render justice.

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For Appellant(s): Mr. V.Jaiharisudhan

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For Respondent(s):Mrs.M.Sneha, Special Counsel for Health and Family Welfare Department for R2 to R5

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JUDGMENT

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(Delivered by the Hon'ble Chief Justice)

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Impugning the order dated 26.2.2026 passed by the learned

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Single Judge in W.P.No.47974 of 2025, the unsuccessful petitioner

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has filed this writ appeal.

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

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W.A.No.760 of 2026

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By proceedings dated 6.2.2025 of the fifth respondent, the appellant, who had not cleared his First Year MBBS Examination in four attempts was discharged and relieved.

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Assailing the proceedings dated 6.2.2025 of the fifth respondent, the appellant filed writ petition. The learned Single Judge, vide the order impugned in his appeal, referring to Regulation No.7.7 of the Regulations on Graduated Medical Education (Amendment), 2019, held that more than four attempts shall not be allowed for a candidate to pass the first professional examination. As the appellant did not pass the first professional examination despite grant of four attempts, the writ petition was dismissed.

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Learned counsel for the appellant submitted that order discharging the appellant suffers from procedural irregularity and permanently thwarts the appellant’s professional career and, therefore, the same warrants interference. He further submitted that certain attempts were restricted appearances or sessions in which the appellant was expressly instructed not to write certain

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Page 3 of 8

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

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W.A.No.760 of 2026

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subjects and counting such appearances as full attempts is irrational, illegal and contrary to established principles governing academic evaluation.

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Learned Standing Counsel for the respondents submitted that the authorities have discharged the appellant strictly in accordance with the Regulations and, in as much as the validity of the said Regulations has already been upheld up to the Supreme Court, the order passed by the learned Single Judge does not warrant any interference.

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We have heard learned counsel on either side and perused the order passed by the learned Single Judge.

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At the outset, it is apposite to refer to Regulation No.7.7 of the Regulations on Graduated Medical Education (Amendment), 2019), which reads thus:

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"7.7. No more than four attempts shall be allowed for a candidate to pass the first Professional examination. The total period for successful

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

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W.A.No.760 of 2026

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completion of first Professional course shall not exceed four (4) years. Partial attendance of examination in any subject shall be counted as an attempt."

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The validity of the said regulation was upheld by a Division Bench of the Delhi High Court in Sachin & Ors. vs. Union of India and Ors.¹ , observing that the petitioners therein had failed to dislodge the presumption of constitutionality existing in favour of the impugned Regulations. It was further observed that the petitioners do not have a legitimate or a vested right to get a degree or get another attempt.

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Challenge to the said decision of the Delhi High Court was rejected by the Supreme Court vide order dated 10.2.2023 passed in SLP (C) No.22716 of 2022.

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The appellant did not place on record any provision which permits relaxing the said Regulation and affords one additional chance to the candidate to clear the first Professional Examination, even on sympathetic considerations. When the authorities have categorically opined that the appellant had exhausted the maximum attempts

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1 MANU/DE/5462/2022

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W.A.No.760 of 2026

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permissible, the writ court cannot sit in appeal over the said decision and once again analyze whether the attempt was a restricted attempt or a regular attempt. In any event, the educational authorities are the best qualified persons to assess the academic performance of a student. The order of the learned Single Judge, in our view, does not warrant any interference.

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For the foregoing reasons, the writ appeal is dismissed. There shall be no order as to costs.

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(SUSHRUT ARVIND DHARMADHIKARI,CJ) (G.ARUL MURUGAN,J) 26.03.2026 Index : Yes/No Neutral Citation : Yes/No sasi

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W.A.No.760 of 2026

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To: