Delhi High Court Holds Fragmented Postgraduate Residency Satisfies 1095‑Day Requirement; Quashes AIIMS Rejection

A single‑judge bench of Justice Jasmeet Singh heard a challenge to AIIMS Delhi's decision to cancel the candidature of a candidate who secured All India Rank 4 in the INI‑SS for DM Critical Care Medicine, on the ground that his three years’ postgraduate residency was completed in fragments across three recognised institutes. The petition assailed the rejection dated 02.01.2026 as arbitrary and violative of Articles 14 and 16.

The Court allowed the petition and held that the prospectus requirement of 1,095 days was satisfied by cumulative service across institutions; the impugned rejection letter was quashed. The Court emphasised that “Any eligibility condition must be clear, explicit and uniformly applicable,” and observed that “merit and fairness prevails over technicalities.” The Court, in its reasoning, observed: “Therefore, it is held that the petitioner’s tenure even if physically fragmented in parts totalling to 1095 days in the same discipline falls within the parameters of Clause 4.3.2 of the prospectus for the Institute of National Importance Super‑Specialty Entrance Test for the January 2026 session issued by the respondent No. 1 Institution. Consequently, the impugned rejection letter dated 02.01.2026 is hereby quashed and set aside.”

Background

The petitioner completed MBBS in 2021 and obtained MD (Anaesthesiology) after serving 15 days at Pramukhswami Medical College, 54 days at AMC MET Medical College and 1,026 days at GCS Medical College, totalling 1,095+ days as certified by Gujarat University and the degree‑granting institute. He applied for the INI‑SS (January 2026) and appeared in the process; AIIMS issued an initial admit card and included him in results but later cancelled his candidature contending that the 1,095‑day requirement implied continuity or completion at a single institute. The petitioner contended that neither the AIIMS prospectus nor the NMC/PGME Regulations, 2023 required that the tenure be from a single institute, and that his fragmented tenure arose from authorised counselling shifts and pandemic‑related rescheduling.

AIIMS defended its interpretation as an academic standard necessary to ensure minimum clinical competence and relied on a Coordinate Bench decision in Dr. Deepak Suresh Kumar. The Court considered the settled principle that judicial interference in academic policy should be cautious but retained where decisions were arbitrary or contrary to law, citing All India Shri Shivaji Memorial Society v. State of Maharashtra and related authority. The Court found Clause 4.3.2 of the AIIMS prospectus silent on a single‑institute requirement and held that the institute had no licence to add an unstated condition. The Court noted that Gujarat University and the degree‑granting college certified completion of the required period and that AIIMS had multiple opportunities during the process to raise objections but had not done so until the final stage. The Court therefore concluded that the petitioner’s cumulative training met the eligibility criteria, quashed the cancellation dated 02.01.2026 and allowed the writ petition. The Court also recorded that an interim direction of 19.01.2026 had restrained allotment of the seat pending final adjudication; the petition was allowed and documents were taken on record.

Case No.: W.P.(C) NO. 78/2026 Case Title: MEET BHADRESH SHAH v. ALL INDIA INSTITUTE OF MEDICAL SCIENCES & ORS. Appearances: For the Petitioner(s): Ms. Anushree Kapadia, Mr. Pranay Bhardwaj, Mr. Shivank Singh, Advocates For the Respondent(s): Mr. Anand Varma, Mr. Ayush Gupta, Advocates; Mr. Kanav Vir Singh (SPC) for R‑2; Mr. Siddharth Garg, Mr. Himanshu Chaubey, Mr. Srijan Sinha, Ms. Lihzu Shiney Konyak, Mr. Srajan Yadav, Ms. Trisha Garimala for R‑3; Mr. Kapil Midha, Ms. Muskaan Garg for R‑5; Mr. T. Singhdev, Mr. Abhijit Chakravarty, Mr. Tanishq Srivastava, Mrs. Yamini Singh, Mr. Vedant Sood for NMC.