Country Lacks Enough Qualified Doctors: Supreme Court Orders Grant Of Medical Degrees To Students With Invalid Tribe Certificate
The Court ordered each doctor to pay Rs 10 Lakhs to compensate the students who were originally denied admission.
The Supreme Court has allowed two medical students to receive their medical degrees despite their tribe certificates being declared invalid, stating that wasting their years of medical training would not be in the best interest of society.
The Bench observed that, as the country faced a shortage of qualified medical professionals, these individuals should be permitted to serve the public.
The Court was hearing appeals of persons who secured medical school admissions using tribe certificates that were later found to be invalid. The High Court had previously refused to help them because of the "suppression of facts".
The Bench of Justice Dipankar Datta and Justice Rajesh Bindal observed, "As it is, the country lacks enough qualified doctors. Granting partial relief to the appellants by directing the University to issue them the degrees/certificates thereby entitling them to join the medical profession, on facts and circumstances, would not compromise merit; rather, it would enable qualified doctors to serve the public. The service that these appellants could render to the society in the long run would outweigh the consequences stemming from the flaws in the admission process, which have subsequently come to the fore. A pragmatic view is what requires to be adopted. However, any undertaking given by the appellants not to claim reservation benefits in future would certainly not suffice. We are of the considered opinion that the appellants cannot be allowed to go scot-free so easily. It can hardly be ignored that in the process of admission based on certificates subsequently found invalid, the appellants had deprived eligible candidates who could have secured admission in their place on the basis of their genuine tribe claim; hence the appellants have to pay some price."
Advocate on Record Amol B. Karande appeared for the Appellants, while Advocate on Record Aaditya Aniruddha Pande appeared for the Respondents.
Facts of the case and Impugned Order
The orders impugned in these appeals, dismissing the appellants’ writ petitions, wherein orders of invalidation of the tribe certificates passed by the Scrutiny Committee were under challenge, now impede the issuance of such degrees/certificates.
Before the Bombay High Court, the case involved two petitioners: Sayanna, who worked as a Livestock Development Officer, and his son, Vivek Kumar, who was a student. Both individuals claimed to belong to the "Mannervarlu" Scheduled Tribe. However, the Caste Scrutiny Committee invalidated their caste certificates, leading them to file separate writ petitions before the High Court.
The High Court found that Sayanna’s caste certificate was originally invalidated as far back as October 1983. Although he appealed that decision, his appeal was dismissed in April 1984. Despite this, Sayanna continued in his government service and only challenged the 1984 dismissal in January 2021—nearly 37 years later—once his son’s own caste claim came under scrutiny.
When Vivek Kumar applied for his caste validity, both he and his father filed affidavits to support the claim. Crucially, they failed to disclose that Sayanna’s own claim had been rejected decades earlier. The court noted that Sayanna remained silent about this history during his recorded statements, which the judges characterized as a deliberate attempt to mislead the Scrutiny Committee.
The Scrutiny Committee conducted a detailed investigation into the family’s school and revenue records from 1963 to 1987. The investigation revealed that the school entries for several close relatives were inconsistent with the "Mannervarlu" claim. More significantly, the Committee discovered that the original school records for Sayanna and other relatives had been tampered with; original caste entries were circled and overwritten with the preferred tribe name.
The High Court refused to exercise its discretion in favor of the petitioners. The Court emphasized that the father and son did not come to the court with "clean hands" and showed "dishonest conduct" by suppressing material facts. The court ruled that the Scrutiny Committee was justified in rejecting the claims based on the manipulated evidence and the history of non-disclosure. Consequently, the high court dismissed both petitions, confirming that the petitioners were not entitled to the Scheduled Tribe status they sought. Hence, they approached the Supreme Court.
Contention of the Parties
The Counsel for the Appellants submitted that since they have succeeded in the examinations by dint of their merit, they may be allowed to reap the benefits of their hard labour and direction be issued to the University to issue the degrees/certificates on their specific undertaking, which may be recorded, that they shall not claim any future benefit of reservation.
The Respondents vehemently said that the admission of the appellants in the medical courses being void ab initio, no benefit ought to be allowed to be reaped.
Observations of the Court
The Court observed, "That the appellants secured admission based on tribe certificates, which have since been cancelled, is not in doubt. Nonetheless, sight cannot be lost that their tribe certificates were invalidated after they had graduated. Bearing in mind the fact that the appellants have completed their curriculum for the medical courses and ultimately succeeded in the examinations written by them, we are of the considered opinion that refusing even partial relief to them would not be in the best interests of society. After all, if indeed partial relief is refused, not only would the two seats occupied by the appellants go to waste, their efforts in succeeding in the examinations would also be of little use for society. It is nobody’s case that the appellants succeeded in the examinations other than on merits."
The Court ordered the two appellants, Vivek and Sachin, to deposit Rs 10,00,000 (10 Lakhs) each with the Vice-Chancellor of the University. This payment had to be made within three months. The Court specifically directed that this money was not just a fine, but was intended for the "deprived candidates"—the students who originally lost their medical seats because of the appellants' invalid claims.
The Court instructed the University to issue the medical degrees and certificates within 24 hours of receiving the deposit. Once they received these documents, the appellants were legally permitted to enrol with the relevant medical councils and begin their careers as doctors.
Accordingly, the Court modified the impugned orders and disposed of the appeals.
Cause Title: Vivek Kumar v. The State of Maharashtra & Ors. [Civil Appeal 3089 of 2026] and another connected matter.
Appearances:
Appellants: Advocate on Record Amol B. Karande, Advocate Ashutosh Srivastava, Advocate Akshada, Advocate B Lakshmi Pallesh.
Respondents: Advocate on Record Aaditya Aniruddha Pande, Advocate on Record M/s Black & White Solicitors, Advocate on Record Shirish K. Deshpande, Advocate on Record Sarad Kumar Singhania, Advocate Rukhmini Bobde, Advocate Siddharth Dharmadhikari, Advocate Shrirang B. Varma, Advocate Vinayak Aren, Advocate Jatin Dhamija, Advocate Aiswharya Nigam, Advocate Suhaskumar Kadam, Advocate Rucha Pravin Mandlik, Advocate Viraj Parakh, Advocate Raghav Arora, Advocate Rashmi Singhania.
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