A) ABSTRACT / HEADNOTE

The judgment examines the legality of continued academic exclusion of postgraduate medical students arising from bail conditions imposed during pendency of a criminal prosecution. The appellants, three postgraduate residents in M.D. Gynaecology and Obstetrics, were implicated in a criminal case involving allegations of ragging and abetment to suicide following the death of a junior resident. Though bail was granted by the High Court, stringent conditions effectively barred the appellants from entering their college and hospital, thereby preventing continuation of their medical education and residency training.

The Supreme Court scrutinised whether such a restriction could be sustained either under Section 6(1) of the Maharashtra Prohibition of Ragging Act, 1999 or under the Medical Council of India Regulations. The Court found that the suspension order was mechanically passed solely due to registration of an FIR, without recording any prima facie satisfaction as mandated by statute. It held that neither the 1999 Act nor the 2009 Ragging Regulations were attracted in absence of a finding of guilt.

Balancing the presumption of innocence, the right to livelihood and education under Article 21, and the interests of prosecution, the Court ruled that denial of academic continuation amounted to an additional punitive consequence without trial. The judgment clarifies limits on judicial discretion in imposing bail conditions and reinforces that academic progression cannot be sacrificed merely due to pendency of criminal proceedings.

Keywords: Ragging law, Bail conditions, Medical education, Article 21, Presumption of innocence

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case arises from a tragic incident involving the suicide of a postgraduate medical student, which led to criminal prosecution of her seniors on allegations of harassment and ragging. The incident triggered institutional, criminal, and regulatory responses simultaneously, creating a complex intersection between criminal justice administration and medical education governance.

The appellants were not undergraduate students but licensed medical graduates undergoing specialised postgraduate training, a stage which mandates continuous hospital residency. Following registration of the FIR, the Dean of the institution suspended the appellants. Subsequently, while granting bail, the High Court imposed conditions barring them from entering the college and hospital premises.

This condition effectively froze the appellants’ academic progression and residency training. Despite investigation being complete and witness statements recorded under Section 164 CrPC, the High Court refused to relax the condition, observing that the appellants could resume education after conclusion of trial.

The Supreme Court was thus called upon to examine whether continuation of education during trial could be denied as a collateral consequence of bail conditions, and whether such denial comported with statutory safeguards and constitutional guarantees. The judgment situates itself within evolving jurisprudence on proportionality of bail conditions and recognition of education as an intrinsic facet of personal liberty under Article 21.

D) FACTS OF THE CASE

The appellants, after completing MBBS, were pursuing M.D. in Gynaecology and Obstetrics at Topiwala National Medical College and were serving as resident doctors at B.Y.L. Nair Charity Hospital. They had completed two of the three years of postgraduate training.

A junior resident, Dr. Payal Tadvi, died by suicide on 22.05.2019. Initially, proceedings were registered under Section 174 CrPC. Following a complaint by the deceased’s mother alleging harassment, an FIR was lodged under Section 306 IPC, Section 4 of the Maharashtra Prohibition of Ragging Act, 1999, and provisions of the SC/ST (Prevention of Atrocities) Act, 1989.

On 27.05.2019, the Dean suspended the appellants citing registration of FIR and alleged non-cooperation. On the same date, the Anti-Ragging Committee submitted its report recommending suspension, though the suspension order did not reference this report.

The appellants were arrested and later granted bail by the High Court. Bail conditions included prohibition on entering the college and hospital and suspension of medical licences. Though licence suspension was later recalled, the academic entry restriction remained.

Repeated requests for relaxation were rejected, prompting the present appeals challenging the non-relaxation of condition prohibiting entry into the institution.

E) LEGAL ISSUES RAISED

i. Whether a bail condition prohibiting entry into an educational institution can continue after completion of investigation?
ii. Whether suspension of students without recording prima facie satisfaction under Section 6(1) of the 1999 Act is legally sustainable?
iii. Whether denial of academic continuation during trial violates Article 21 of the Constitution?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellants submitted that the presumption of innocence entitled them to continue education. It was argued that Section 6(1) of the 1999 Act mandates a preliminary finding, which was absent.

Reliance was placed on Sumit Mehta v. State (NCT of Delhi) and Kunal Kumar Tiwari v. State of Bihar to contend that bail conditions must not be arbitrary or punitive. It was emphasised that statements of witnesses had already been recorded under Section 164 CrPC, eliminating apprehension of influence.

The appellants argued that denial of residency training would irreversibly damage their careers, amounting to punishment without trial and infringing Article 21.

G) RESPONDENT’S ARGUMENTS

The counsels for the State and complainant contended that the suspension was based on Anti-Ragging Committee findings and that academic presence could influence witnesses.

It was argued that MCI Regulations prohibit migration and that appellants could resume education post-trial. The continued operation of suspension was relied upon to justify denial of entry into the institution.

H) JUDGEMENT 

The Supreme Court undertook a detailed balancing exercise between individual liberty and interest of prosecution. It observed that the suspension order did not record any prima facie finding as required by Section 6(1). The Court found that the suspension was passed merely due to FIR registration, rendering it legally unsustainable.

The Court held that Ragging Act provisions and 2009 Regulations apply only after a finding of guilt. Since no such finding existed, statutory consequences could not be triggered.

On bail conditions, the Court reiterated that conditions must advance the trial process and not impose extraneous punishment. Preventing the appellants from completing their postgraduate training was held to be disproportionate and violative of Article 21.

The Court emphasised that even convicts are permitted educational pursuits, and denying the same to undertrial accused would be antithetical to constitutional values.

The appeals were allowed and condition prohibiting entry into the college and hospital was relaxed subject to safeguards ensuring non-interference with witnesses.

a) RATIO DECIDENDI

The ratio of the judgment is that pendency of criminal prosecution cannot, by itself, justify denial of educational and professional continuity. Any suspension or restriction must strictly comply with statutory preconditions. Bail conditions must bear direct nexus with administration of justice.

b) OBITER DICTA

The Court observed that State authorities must facilitate, not frustrate, academic development, and that postponing education until after trial is neither reasonable nor humane.

c) GUIDELINES

i. Suspension under Section 6(1) requires prima facie satisfaction
ii. Bail conditions must not impose indirect punishment
iii. Academic rights form part of Article 21
iv. Recording of witness statements reduces apprehension of influence

I) CONCLUSION & COMMENTS

The judgment reinforces constitutional discipline in criminal procedure and academic governance. It prevents educational exclusion from becoming a surrogate punishment. The ruling sets a critical precedent for professional students facing criminal trials, ensuring that justice does not extinguish futures before guilt is established.

J) REFERENCES

a) Important Cases Referred

i. Sumit Mehta v. State (NCT of Delhi), (2013) 15 SCC 570
ii. Kunal Kumar Tiwari v. State of Bihar, (2018) 16 SCC 74

b) Important Statutes Referred

i. Constitution of India, Article 21
ii. Maharashtra Prohibition of Ragging Act, 1999
iii. Code of Criminal Procedure, 1973
iv. Medical Council of India Regulations, 2000 & 2009