SC SAFEGUARDS MBBS DEGREE AFTER CANDIDATE’S ST CERTIFICATE IS INVALIDATED:

The Supreme Court recently permitted a medical student to retain and complete his MBBS degree even though his Scheduled Tribe (ST) certificate was later declared invalid. The Court took this view primarily because the student had already completed his medical education while proceedings regarding the validity of his caste claim were still pending. At the same time, the Court made it unequivocally clear that he would not be entitled to claim any future benefits under the ST category.

The matter reached the Supreme Court as an appeal against a decision of the Bombay High Court. The High Court had affirmed the order of the Scrutiny Committee, which declared the petitioner’s claim of belonging to the ‘Mannervarlu’ Scheduled Tribe as invalid and had consequently confiscated his tribe certificate. The petitioner had secured admission to the MBBS program at a medical college (arrayed as Respondent No. 3) against a seat reserved for candidates belonging to the Scheduled Tribe category. His admission had been based on his assertion that he was a member of the Mannervarlu tribe.

While his claim was under examination before the Scrutiny Committee, the petitioner pursued and completed all requirements of the MBBS course. After evaluating the materials placed before it, the Scrutiny Committee eventually rejected his caste claim and invalidated his ST certificate. This prompted the petitioner to challenge the decision before the High Court, and later, through a Special Leave Petition, before the Supreme Court.

During the hearing before the apex court, Senior Advocate Sudhanshu S. Choudhari, appearing for the petitioner, submitted that although the petitioner had been admitted under the ST quota, he had subsequently paid the entire tuition fee applicable to students admitted under the General category. It was further argued that once the medical college had completed its admission process and allotted all seats, the seat taken by the petitioner could not practically be re-allocated to another candidate. The bench, comprising Chief Justice of India B.R. Gavai and Justice Vijay Bishnoi, took note of this circumstance when assessing the equities of the case.

The Court observed that the student had already undergone the entire duration of medical training during the pendency of the dispute, and that declining protection at this stage would effectively deprive him of the benefit of several years of medical education. The bench remarked that allowing the education to be nullified would result in a significant and irreversible loss, especially given the effort and substantial resources that had already gone into his training. The Court noted that the medical education, once completed, could not be retroactively undone or reassigned to another candidate.

In light of these considerations, the Supreme Court decided to protect the MBBS degree obtained by the petitioner. The Court held that the education he had completed could stand and need not be disturbed. At the same time, the bench imposed a clear limitation: although his degree would remain valid, he would not be permitted to claim any present or future advantage on the basis of belonging to the Scheduled Tribe category. This meant that no reservation benefits, whether in service, postgraduate admissions, or elsewhere, could be invoked by him going forward.