New Delhi: The Supreme Court, in a recent ruling directing the issuance of pending degrees to Master of Dental Surgery (MDS) graduates, highlighted the shortage of super-speciality doctors in the field of dentistry.
The bench, comprising Justice BR Gavai and Justice KV Viswanathan, was hearing an appeal by MDS graduates (2016-19 batch) from dental colleges in Madhya Pradesh. The graduates challenged the Madhya Pradesh High Court’s decision to cancel their admissions, which were granted in 2016.
Case Background
The dispute arose after the Regulatory Authority canceled the appellants’ admissions on the grounds that they had not participated in the counselling process, as required by the Supreme Court’s 2016 order. The appellants, who completed their Bachelor of Dental Surgery (BDS) from Karnataka, Gujarat, and Maharashtra, were deemed to have violated the admission process. The cancellation was subsequently upheld by the appellate authority.
The appellants challenged the decision through a writ petition in the Madhya Pradesh High Court, which initially granted an interim stay. However, upon completion of their MDS course, the High Court dismissed the petition and upheld the cancellations. The graduates then approached the Supreme Court.
Supreme Court Observations
The appellants, represented by Senior Advocate Kapil Sibal, argued their case, while Sr Advocate Saurabh Mishra (for the State of Madhya Pradesh) and Sr Advocate Gaurav Sharma (for the Dental Council of India) contended that the admissions were invalid since the appellants bypassed the counselling process.
The Supreme Court dismissed the argument, noting that other students similarly situated—having completed their BDS from Madhya Pradesh—were allowed to retain their MDS degrees.
“The fact remains that similarly circumstanced students, who have passed their BDS Course from the State of Madhya Pradesh, have got their Post Graduate Degrees (MDS Course),” the Court stated.
The Court further rejected the claim that the appellants’ cases involved greater irregularities than those with BDS degrees from within the state. Emphasizing the lack of super-speciality doctors in dental sciences, the Court underscored the irreparable loss the appellants would face if their degrees were not regularized.
“It is commonly known that there is a dearth of super-speciality doctors even in the field of dental science. If the admission of the appellants is not regularized, the education undertaken by them would go to waste,” the bench observed.
Ruling
The Supreme Court quashed the High Court’s decision and the cancellation orders issued by the Regulatory Authority and Appellate Authority. The Court allowed the appeal, regularized the appellants’ admissions, and directed the issuance of their MDS degrees.
The bench clarified that the ruling was specific to the unique circumstances of this case and should not serve as a precedent for other matters.
“In the peculiar facts and circumstances of the case, we are inclined to allow the appeal… This order cannot be treated as a precedent in any other matter,” the Court concluded.
