Medical Training Can’t Be Replaced By Online Classes: Andhra Pradesh HC Upholds Extended Internship For Foreign Medical Graduates
A group of Foreign Medical Graduates challenged the denial of permanent registration after completing a one-year internship.
Justice Kiranmayee Mandava, Andhra Pradesh HC
The Andhra Pradesh High Court emphasized the indispensable nature of hands-on training and clinical experience in the field of medicine. The Court said that medical education is not limited to theoretical knowledge but inherently involves practical components such as skill-based training, anatomical dissections, direct patient interaction, and collaborative learning through case-based problem solving.
A Bench of Justice Kiranmayee Mandava stated, “As noted from the proceedings of the 1st respondent, the students were instructed to continue their internship at their allotted medical college and Hospital until further orders of A.P.Medical Council. In the light of the circulars of the Government of India on the issue, the stages of medical education designed to impart required practical training cannot be overlooked.”
This observation was made while adjudicating a writ petition filed by a group of foreign medical graduates (FMGs), who challenged the decision of the Andhra Pradesh Medical Council (Respondent No. 1) refusing to grant them permanent registration certificates. These graduates had completed their MBBS degrees from foreign universities and had cleared the Foreign Medical Graduate Examination (FMGE) conducted by the National Board of Examination in Medical Sciences. They also possessed the necessary Screening Test Pass Certificates.
Following this, the petitioners underwent a one-year internship at designated medical colleges, based on allotment orders issued to them. They contended that this internship, in accordance with a circular issued by the National Medical Commission (NMC) dated 09.05.2023, met the prescribed requirement of a 12-month minimum period. Upon completion, they applied for permanent registration, which was denied by the Council, citing pending verification of their documents.
The respondents argued that new circulars issued by the NMC, including one dated 07.06.2024, mandated a longer internship of two to three years for FMGs who had attended any part of their medical education online. This extended internship, as per the revised guidelines, was necessary to ensure adequate clinical exposure and to address concerns regarding fraudulent certification and insufficient offline training among some foreign graduates.
The Court also took note of the background leading to the issuance of these guidelines. It was revealed that the certificates submitted by some students, which claimed that their education was conducted offline, were later discovered to be invalid or fraudulent. In response, the authorities introduced stringent norms requiring all such students, regardless of individual claims, to undergo a two- to three-year Compulsory Rotating Medical Internship (CRMI), effectively repeating the 12-month schedule.
The Court dismissed the petitioners’ challenge, including the plea of Petitioner No. 13, who argued that her course was conducted entirely offline and that her stay in India was brief. The Court ruled that such individual circumstances could not override the broader regulatory framework designed to ensure the integrity and quality of medical training. The Court added, “The medical profession, is something which requires practical knowledge and clinical training, which cannot be substituted by onlines classes. The regular medical course requires clinical skills training, dissections in laboratories to understand the human anatomy patient interaction, team based learning such as case studies and problem solving exercises.”
Hence, the petition challenging the requirement of an extended internship was dismissed.
Cause Title: Chukka Divya Keerthana Reddy & Ors. v. The Ap Medical Council & Ors., [APHC010000792025]
Appearance:
Petitioners: Advocates MR Tagore and Kasim Nagasaim
Respondents: Advocates VV Anil Kumar, Vivek Chandra Sekhar S
