Supreme Court: The instant judgment raises an important issue concerning the consequences of admission obtained based on caste or tribe certificates that are subsequently declared invalid by the competent Scrutiny Committee. Invoking power under Article 142 of the Constitution, a Division Bench of Dipankar Datta and Rajesh Bindal, JJ., directed the issuance of degrees to appellants who had secured admission to medical courses on reserved seats based on tribe certificate.
However, the Court acknowledged the injustice caused to genuine candidates who might have secured admission and therefore, held that the appellants could not be allowed to go “scot-free” and must bear some consequence for the irregular admission. It directed each appellant to deposit ₹10,00,000 with the Vice-Chancellor of the Maharashtra University of Health Sciences, Nashik (the University) and the same to be released to the deprived candidates.
In the instant matter, the appellants had secured admission to medical courses on seats reserved for members of Scheduled Tribes on the basis of tribe certificates produced by them at the time of admission. Subsequently, the validity of these certificates was scrutinized by the competent Scrutiny Committee, which found the certificates to be invalid and cancelled them.
By the time the certificates were invalidated, both appellants had already completed their respective medical courses and had also successfully cleared all examinations conducted by the University. Ordinarily, upon passing these examinations, they would have been entitled to receive their medical degrees from the university. However, because their tribe certificates were invalidated and the High Court had upheld such invalidation, the university declined to issue the degrees.
Aggrieved by the refusal and the dismissal of their writ petitions before the High Court, the appellants approached the Supreme Court seeking relief.
The Court observed that there was no dispute that the appellants had secured admission on the basis of tribe certificates which were subsequently cancelled. At the same time, it noted that the invalidation of the certificates occurred only after the appellants had already completed their courses and passed the examinations.
The Court considered the broader implications of refusing relief. It emphasised that denying the degrees would result in the seats occupied by the appellants going waste and would render their academic efforts meaningless. The Court also pointed out that it was “nobody’s case that the appellants succeeded in the examinations other than on merits.”
Taking a pragmatic view, the Court highlighted that the country lacks enough qualified doctor and allowing the appellants to practice medicine would serve the larger interests of society, as they had demonstrated the required competence by successfully completing the course and examinations.
However, the Court also acknowledged that the appellants had gained admission through certificates that were ultimately declared invalid. As a result, they had deprived eligible candidates with genuine tribe claims of seats that should have been allotted to them. Therefore, the Court held that the appellants could not be allowed to escape the consequences entirely.
To balance the equities, the Court held that while the appellants could be granted partial relief in the interest of society, they must also bear a financial consequence for having occupied seats meant for genuine candidates.
The Court disposed of the appeals with the following directions:
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Each appellant must deposit ₹10,00,000 with the Vice-Chancellor of the University within three months.
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Upon such deposit, the University must issue the medical degrees or certificates to the appellants within 24 hours.
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After receiving the degrees, the appellants would be entitled to enroll with the appropriate medical council and practice the profession.
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The University must identify the candidates who were deprived of admission due to the appellants occupying reserved seats.
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The amounts deposited by the appellants are to be released in favour of such deprived candidates.
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If the appellants fail to deposit the amount within the stipulated period, the Court may reconsider the relief granted.
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The appellants’ undertaking not to claim any reservation benefits in the future based on the invalidated tribe certificates was recorded.
The Court clarified that the invalidation of the tribe certificates by the High Court would remain undisturbed. The Court further clarified that directions granting relief were issued in exercise of the Court’s power under Article 142 of the Constitution and therefore not to be treated as a precedent.
[Vivekkumar v. State of Maharashtra, Civil Appeal No. 3089/2026, decided on 25-2-2026]
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