The packed courtroom at the Orissa High Court on Tuesday morning saw a familiar tension-government policy on one side, a young doctor’s career on the other. By the afternoon, the Bench made it clear that administrative convenience cannot trump equality. In a detailed ruling, the court directed the Odisha government to issue a No Objection Certificate (NOC) to Dr Subrat Jamadar, clearing his path to appear in counselling for a sponsored DNB postgraduate medical seat.
Background
Dr Jamadar, a Medical Officer under the Odisha Medical Health Services (OMHS), is currently posted at the District Headquarters Hospital in Paralakhemundi, Gajapati district. After qualifying NEET-PG, he sought permission from the State to participate in counselling conducted by the National Board of Examinations in Medical Sciences for Sponsored DNB (Post MBBS) seats.
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The trouble began when the Health and Family Welfare Department declined to issue an NOC. The refusal was based on a 2022 departmental committee decision which allowed NOCs for regular PG and DNB courses but specifically barred doctors from applying for sponsored DNB programmes. Left with little choice, Dr Jamadar knocked on the High Court’s door, alleging discrimination.
Court’s Observations
During the hearings, the Bench examined the State’s justification closely. The government argued that sponsored DNB seats require the employer to pay salary during the study period, and policy considerations allowed it to deny permission.
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The judges were unconvinced. They noted that the Odisha Service Code already permits study leave for higher medical education and does not distinguish between sponsored and non-sponsored DNB courses. “The State has failed to demonstrate any intelligible differentia,” the Bench observed, adding that doctors governed by the same service rules cannot be treated differently without valid reasons.
The court also pointed out a contradiction in the government’s own policy—one clause permitted NOCs for DNB courses through NEET, while another denied them only for sponsored DNB seats. “Such selective denial,” the judges remarked, “does not satisfy the constitutional requirement of equality.”
The Bench further reminded the State that reasons for denying a benefit must be evident in the decision itself, not invented later through affidavits. The absence of clear reasoning, the court said, made the refusal vulnerable to judicial review.
Decision
Allowing the writ petition, the Orissa High Court directed the authorities to issue an NOC to Dr Jamadar by 2 January 2026, enabling him to participate in the sponsored DNB counselling before the notified deadline. The court held that the blanket refusal was arbitrary and violated Article 14 of the Constitution, bringing the matter to a close at the stage of the court’s final order.
Case Title: Dr. Subrat Jamadar vs State of Odisha & Others
Case No.: W.P.(C) No. 28196 of 2025
Case Type: Writ Petition (Civil) under Articles 226 & 227 of the Constitution
Decision Date: 24 December 2025