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IN THE SUPREME COURT OF INDIA Reportable

NEET-PG 2022 Internship Deadline: Supreme Court Upholds Cut-Off Date

Shikhar & Anr. vs National Board of Examination & Ors.

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Key Takeaways

• A court cannot extend the internship deadline merely because some students face hardships due to Covid-related delays.
• Eligibility criteria for NEET-PG admissions are determined by the National Board of Examination and are not subject to judicial interference unless arbitrary.
• Judicial review in academic policy matters is limited; courts defer to the expertise of educational authorities.
• Cut-off dates are essential for maintaining the integrity of academic schedules and cannot be altered without significant justification.
• Policy decisions regarding educational timelines are within the executive's domain, and courts should avoid micromanaging these aspects.

Content

NEET-PG 2022 Internship Deadline: Supreme Court Upholds Cut-Off Date

Introduction

In a significant ruling, the Supreme Court of India has upheld the cut-off date for the completion of internships for candidates appearing for the NEET-PG 2022 examination. The decision came in response to a writ petition filed by medical aspirants challenging the deadline set by the National Board of Examination (NBE). The Court emphasized the importance of maintaining academic schedules and the executive's role in determining eligibility criteria.

Case Background

The petition was filed under Article 32 of the Constitution by doctors aspiring to take the NEET-PG 2022 examination. The NBE had set a deadline of May 31, 2022, for the completion of internships, which was later extended to July 31, 2022. The petitioners argued that this extension still left many students from various states unable to meet the deadline due to delays caused by their deployment in Covid management duties.

The petitioners highlighted that in several states, internships commenced later than usual due to the pandemic. For instance, in states like Kerala and Bihar, internships began in August and October 2021, respectively. They contended that the cut-off date should be further extended or that the time spent on Covid duties should count towards the internship requirements.

What The Lower Authorities Held

Initially, the NBE had set the cut-off date for internship completion as May 31, 2022. However, following the petitioners' representation, the NBE extended this date to July 31, 2022. Despite this extension, the petitioners remained dissatisfied, leading to the current petition before the Supreme Court.

The Court's Reasoning

The Supreme Court, while acknowledging the hardships faced by some students, emphasized that the determination of cut-off dates falls within the policy domain of the executive and regulatory authorities. The Court referred to previous judgments that established the principle that courts should exercise caution in matters concerning academic policies, including eligibility criteria for examinations.

The Court noted that extending the cut-off date further would disrupt the entire examination schedule, which was already set to commence on May 21, 2022, with classes expected to start on August 1, 2022. The Additional Solicitor General presented practical difficulties in accommodating the petitioners' requests, highlighting the cascading effects of any changes to the established timeline.

The Court also addressed the petitioners' alternative request to count the time spent on Covid duties towards internship requirements. It ruled that such a decision would involve the Court in micromanaging the curriculum, a function that should remain with educational authorities.

Statutory Interpretation

The Court's ruling underscores the principle that eligibility criteria for examinations like NEET-PG are determined by the relevant authorities based on policy considerations. The Court reiterated that judicial review in such matters is limited and that courts should defer to the expertise of educational institutions unless there is clear evidence of arbitrariness or discrimination.

Constitutional or Policy Context

The ruling is significant in the context of Article 14 of the Constitution, which guarantees equality before the law. The Court clarified that while cut-off dates may exclude certain candidates, this exclusion does not automatically render the criteria arbitrary. The determination of cut-off dates is a policy decision that must consider various factors, including the need to maintain academic integrity and the orderly conduct of examinations.

Why This Judgment Matters

This judgment reinforces the principle that courts should exercise restraint in interfering with academic policies and eligibility criteria. It highlights the importance of maintaining established timelines in educational settings, particularly in the wake of disruptions caused by the Covid-19 pandemic. The ruling serves as a reminder that while individual hardships are important, they must be balanced against the broader implications for the educational system.

Final Outcome

The Supreme Court dismissed the petition, upholding the cut-off date for internship completion as July 31, 2022. The Court emphasized that any further extension would disrupt the academic schedule and that the determination of such dates lies within the executive's purview.

Case Details

  • Case Title: Shikhar & Anr. vs National Board of Examination & Ors.
  • Citation: 2022 INSC 390
  • Court: IN THE SUPREME COURT OF INDIA
  • Bench: Justice Dhananjaya Y Chandrachud, Justice Surya Kant, Justice Bela M. Trivedi
  • Date of Judgment: 2022-04-05

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