Tuesday, June 23

Court Directs State to Issue NOCs and Relieves MBBS Graduates from Mandatory Service Bond Obligations

In a significant relief for MBBS graduates in Chhattisgarh, the Chhattisgarh High Court has ruled that compulsory service bonds executed by medical students automatically stand cancelled if the State Government fails to issue appointment orders within six months of completion of the MBBS course and internship, as mandated under the Chhattisgarh Medical, Dental and Physiotherapy Undergraduate Admission Rules, 2025.

The ruling came from a bench headed by Justice Amitendra Kishore Prasad while hearing petitions filed by MBBS graduates who challenged the State Government’s refusal to grant No Objection Certificates (NOCs) despite the expiry of the statutory six-month period prescribed for issuing appointment orders.

The Court held that the State authorities failed to comply with Rule 10(6) of the 2025 Rules, which clearly states that if appointment orders are not issued within six months after completion of MBBS and internship, the service bond shall be deemed automatically cancelled. Consequently, appointment orders issued by the government on December 24, 2025, after the expiry of the prescribed period, were declared unenforceable and legally ineffective.

Petitioners Completed Internship in 2025

The petitioners had completed their MBBS course from Chhattisgarh Institute of Medical Sciences in 2024 and subsequently finished their compulsory rotating internship between May and June 2025. At the time of admission, they had signed service bonds committing to serve the State Government for two years after completing their studies.

However, despite repeated representations by the graduates, the government did not issue appointment orders within the stipulated six-month period. Instead, authorities initiated counselling for compulsory government service in December 2025 and later issued posting orders for various healthcare facilities in Bijapur and Narayanpur districts.

The graduates argued that since the State failed to meet its statutory obligation within the prescribed timeframe, their bond obligations had already ceased to exist by operation of law. They further contended that the government’s refusal to issue NOCs was preventing them from pursuing higher education and professional opportunities.

State Defends Bond Policy

The State Government opposed the petitions, arguing that the doctors had voluntarily undertaken the service bond at the time of admission and had benefited from subsidised education in government medical institutions.

The government maintained that the bond policy was introduced to address shortages of doctors in rural and remote healthcare facilities and was intended to strengthen public healthcare services. It also argued that the counselling and appointment process had been conducted in accordance with established procedures and that some petitioners had participated in the counselling process.

High Court Emphasises Reciprocal Obligations

After examining the relevant provisions of the 2025 Admission Rules, the Court observed that while students are required to render compulsory government service, the State Government is equally obligated to issue appointment orders within six months of course and internship completion.

The bench noted that Rule 10(6) specifically provides a consequence for non-compliance by the State, namely automatic cancellation of the bond. The Court found that the delay in issuing appointment orders was entirely attributable to the authorities and not the petitioners.

The Court further observed that the authorities attempted to enforce the bond conditions only after the statutory period had already expired and after the legal consequences under Rule 10(6) had taken effect.

Court Orders Immediate Issuance of NOCs

Allowing the petitions, the High Court directed the authorities to immediately issue No Objection Certificates to the affected graduates without demanding any bond penalty. The Court also ruled that the petitioners cannot be compelled to join the postings offered under the delayed appointment orders or participate in counselling linked to the bond obligation.

Additionally, the Court ordered Pt. Deendayal Upadhyay Memorial Health Sciences and Ayush University of Chhattisgarh to confer MBBS degrees upon the petitioners, if not already awarded, without insisting on any NOC related to compulsory service bond compliance.

The judgment is expected to have significant implications for service bond enforcement in medical education and may influence future disputes concerning delayed government appointments under mandatory service bond schemes.

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