A) ABSTRACT / HEADNOTE

Anmol v. Union of India & Ors., Civil Appeal No. 14333 of 2024 ([2025] 2 S.C.R. 1142 : 2025 INSC 256) examines whether rigid reliance on quantified disability thresholds and prescriptive eligibility criteria in Appendix H-1 to the Graduate Medical Education Regulations (Amendment), 2019 can lawfully bar a candidate from admission to MBBS when a functional assessment, reasonable accommodations and assistive technologies may permit successful completion of the course.

The Court applied the purposive mandate of the Rights of Persons with Disabilities Act, 2016 and the doctrine of reasonable accommodation (as explained in Omkar Ramchandra Gond v. Union of India and Om Rathod v. DGHS) to hold that mechanical quantification (and the specific prescription “both hands intact, with intact sensations, sufficient strength and range of motion”) is overbroad and violates principles of equality, dignity and inclusion.

A medical board’s denial of eligibility without a reasoned functional assessment and without considering accommodations was rejected. The separate, detailed functional assessment by Dr. Satendra Singh that tested psychomotor skills in simulation, recommended specific clinical accommodations and concluded the appellant could pursue MBBS, was accepted. The result: admission confirmed and directions to the National Medical Commission (NMC) to revise guidelines, include domain experts and persons with disability, and file an affidavit on progress by 03.03.2025.

Keywords: reasonable accommodation; functional assessment; Disability Assessment Board; Appendix H-1; Rights of Persons with Disabilities Act, 2016.

B) CASE DETAILS 

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal arises from denial of MBBS eligibility by a designated Disability Certification Centre that mechanically applied quantified disability thresholds and the Appendix H-1 prescription requiring “both hands intact…” without a reasoned functional analysis. The appellant, a high-scoring NEET-UG candidate in the PwD category having final computed disability of 58% (locomotor with speech impairment), was declared ineligible.

The High Court dismissed his writ petition on the ground courts cannot substitute expert opinion. On special leave, this Court directed AIIMS to constitute a six-member committee and co-opted Dr. Satendra Singh. The committee produced two reports: five members issued a brief negative conclusion citing existing NMC guidelines and no express reasons; Dr. Singh furnished a detailed functional assessment, simulation testing of psychomotor skills and proposed clinical accommodations and assistive technologies.

The Supreme Court engaged earlier precedents principally Omkar Ramchandra Gond (which emphasised reasonable accommodation under RPwD Act, 2016 and directed NMC to revise guidelines) and Om Rathod—to assess whether the five-member report satisfied the legal standards. The Court rejected mechanical disqualification, accepted Dr. Singh’s interactive, function-focused assessment and directed admission subject to accommodations. The judgment reiterates that Disability Assessment Boards must undertake case-by-case functional competency testing, provide reasons when denying eligibility and keep in view the statutory commitment to inclusion.

D) FACTS OF THE CASE

Anmol obtained a strong NEET-UG rank (2462 in PwD category) and sought admission under the OBC-PwD quota. Medical evaluation recorded locomotor disability 50% (club foot, phocomelia), finger abnormalities and speech & language disability 20%, aggregating to 58%. The Government Medical College, Chandigarh (designated Disability Assessment Board) issued a certificate on 02.09.2024 declaring him ineligible for medical course by relying on quantified disability and Appendix H-1 criteria without explaining the functional basis. The appellant filed a writ petition which was dismissed.

On SLP, this Court directed AIIMS to frame a committee; the AIIMS Board’s five-member report concluded the candidate was not fit under current NMC Guidelines but noted the Guidelines needed revision. Dr. Satendra Singh’s separate report conducted an interactive assessment, tested psychomotor tasks in a simulated skills lab (glass slides, suturing, CPR, catheterisation etc.), observed functional grasp, and proposed phase-wise accommodations (scribes, compensatory time, antivibration gloves, speech-to-text).

The five-member report lacked detailed reasoning on functional assessment; Dr. Singh’s report explained methodology, answered safety and curricular integrity questions, and recommended admission with accommodations. The Court had earlier in Omkar Gond and Om Rathod criticized overbroad rules and mandated functional assessment and reasonable accommodation.

E) LEGAL ISSUES RAISED

i. Whether quantified disability alone can disqualify a candidate from MBBS admission under Appendix H-1 of NMC Regulations?
ii. Whether Disability Assessment Boards can rely on prescriptive requirements like “both hands intact” without individualized functional assessment?
iii. What is the scope and content of reasonable accommodation under Section 2(y), RPwD Act, 2016 in medical education context?
iv. Whether courts may review and direct reassessment when a Disability Assessment Board’s negative opinion lacks reasoned functional analysis?
v. Whether specific clinical accommodations and assistive technologies can render a candidate with benchmark disability fit to pursue MBBS without jeopardizing patient safety or CBME core competencies?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for Petitioner / Appellant submitted that the disability certificate mechanically applied percentage norms and Appendix H-1 without conducting a functional assessment and failed to consider reasonable accommodations and assistive technologies. They argued that mere quantification (58%) cannot extinguish the right to claim admission, citing Omkar Ramchandra Gond and constitutional guarantees of equality and dignity. They urged that interactive simulation, competency testing and accommodations (as undertaken by Dr. Satendra Singh) demonstrate fitness to pursue MBBS and that the Board must give reasoned findings rather than a blanket exclusion.

G) RESPONDENT’S ARGUMENTS

The counsels for Respondent submitted that the Disability Assessment Board and AIIMS majority report followed the extant NMC Guidelines and medical expertise, concluding the candidate was not suitable for competency-based MBBS program. They emphasized that courts should not supplant expert opinion. The respondents highlighted concerns about patient safety and the integrity of clinical competencies if prescriptive physical requirements are relaxed without rigorous evaluation.

H) RELATED LEGAL PROVISIONS

i. Rights of Persons with Disabilities Act, 2016 — definitions, mandate for inclusive education and Section 2(y) on reasonable accommodation.
ii. Graduate Medical Education Regulations (Amendment), 2019 — Appendix H-1 eligibility framework for specified disabilities.
iii. Constitution of India — Article 14 (equality), Article 21 (right to life & dignity), Article 41 (Directive Principles: work & education).
iv. Precedents: Omkar Ramchandra Gond v. Union of India (2024 SCC OnLine SC 2860); Om Rathod v. DGHS (2024 SCC OnLine SC 3130); Vikash Kumar v. UPSC ((2021) 5 SCC 370); Sunanda Bhandare Foundation v. Union of India ((2014) 14 SCC 383); Vidhi Himmat Katariya v. State of Gujarat ((2019) 10 SCC 20) — as distinguished.

I) JUDGEMENT

The Court held that mechanical reliance on quantified disability and prescriptive clauses like “both hands intact…” is incompatible with the purposive objectives of the RPwD Act and the UNCRPD principles. The five-member AIIMS report was rejected because it did not disclose how functional assessment was conducted, failed to assign reasons for ineligibility, and expressly noted the Guidelines required revision.

The Court applied Omkar Ramchandra Gond and Om Rathod holding that Disability Assessment Boards must undertake a case-by-case functional competence assessment, consider reasonable accommodation and state reasons when denying eligibility. Dr. Satendra Singh’s report met the legal standard by employing an interactive assessment, simulated psychomotor tests, answering safety and curricular integrity questions, and proposing phase-wise accommodations and assistive technologies.

The Court accepted Singh’s conclusion that the appellant could pursue MBBS with accommodations, that patient safety would not be jeopardized, and that accommodations would not improperly waive core CBME requirements. Consequently, the Supreme Court confirmed the appellant’s admission to Government Medical College, Sirohi, and directed the NMC to constitute a committee (including persons with disability) to revise guidelines and file an affidavit by 03.03.2025. No costs were ordered.

a. RATIO DECIDENDI

The legal ratio is that quantified disability per se cannot be an automatic disqualification for admission to medical courses; Disability Assessment Boards must perform reasoned, individualized functional assessments and determine whether, with reasonable accommodations and assistive technologies, a candidate can meet the competency outcomes required by CBME.

The prescriptive “both hands intact” requirement is overbroad, ableist, and inconsistent with RPwD Act, 2016 and constitutional principles. Courts can review and direct reassessment where boards fail to give reasons or conduct holistic evaluations; however, expert opinion remains central, provided it follows legal standards of transparency and function-centric testing.

b. OBITER DICTA 

The judgment emphasises that reasonable accommodation extends beyond physical devices to pedagogic and assessment adjustments, and that modern medical practice (robotics, team-based procedures) undermines archaic physical benchmarks. The Court reiterates that inability should not be presumed and that the candidate must be given opportunity to demonstrate competence in simulated settings before exclusion. The Court also underscores the duty of regulatory bodies to include disability experts and persons with disabilities while framing normative criteria.

c. GUIDELINES

i. Disability Assessment Boards must conduct interactive, case-by-case functional assessments aligned to CBME outcomes.
ii. Boards must record reasoned findings when denying eligibility, explaining testing methodology and why accommodations cannot bridge gaps.
iii. NMC to constitute a domain-expert committee (including persons with disabilities) to reformulate guidelines supplanting prescriptive ableist clauses.
iv. Admissions decisions denying candidates are amenable to judicial review and, pending appellate body formation, courts may refer to premier medical institutes for independent opinion.
v. Proposed accommodations (scribes, compensatory time, assistive tech, simulation training) should be weighed against patient safety and feasibility, not foreclosed by rigid physical criteria.

J) CONCLUSION & COMMENTS

The judgment advances disability jurisprudence by operationalising reasonable accommodation as a substantive right essential to equality and dignity. It rejects formalistic, ableist regulatory clauses that foreclose individualized assessment and incentivises regulatory reform that is evidence-based and inclusive. Practically, it requires medical institutions and DABs to adopt transparent protocols, simulation-based competency testing and to document reasons, thereby reducing arbitrary exclusions.

The decision balances deference to medical expertise with constitutional oversight: courts will not substitute experts but will intervene to ensure assessments are holistic, reasoned and rights-compliant. The directions to NMC and the insistence on inclusion of disability experts are systemic remedies likely to reshape admission practices and protect aspirants from procedural and substantive discrimination.

K) REFERENCES

a. Important Cases Referred

Omkar Ramchandra Gond v. Union of India & Ors., 2024 SCC OnLine SC 2860.
Om Rathod v. Director General of Health Services & Ors., 2024 SCC OnLine SC 3130.
Vikash Kumar v. Union Public Service Commission & Ors., (2021) 5 SCC 370.
Vidhi Himmat Katariya and Others v. The State of Gujarat and Others, (2019) 10 SCC 20.
Sunanda Bhandare Foundation v. Union of India, (2014) 14 SCC 383.
Anmol v. Union of India & Ors., Civil Appeal No. 14333 of 2024, [2025] 2 S.C.R. 1142 : 2025 INSC 256.

b. Important Statutes Referred

Rights of Persons with Disabilities Act, 2016 (India).
Graduate Medical Education Regulations (Amendment), 2019 (NMC) — Appendix H-1.
Constitution of India — Article 14, Article 21, Article 41.