In a significant ruling on February 21, 2025, the Supreme Court of India struck down the National Medical Commission's (NMC) guideline that required MBBS candidates to have "both hands intact, with intact sensation and sufficient strength" for admission. The Court ruled that this condition was arbitrary, discriminatory, and unconstitutional, violating the Rights of Persons with Disabilities (RPwD) Act, 2016, and fundamental rights guaranteed under the Indian Constitution.
Background of the Case
The case revolved around a petitioner, a person with a 58% disability, who was denied admission to the MBBS program at Government Medical College, Sirohi, Rajasthan, solely due to the NMC’s eligibility criteria. The petitioner had a 50% locomotor disability, along with a 20% speech and language impairment. Despite being otherwise qualified for medical education, the rigid guideline disqualified him from admission.
The bench, comprising Justice B.R. Gavai and Justice K.V. Viswanathan, found the NMC guideline to be fundamentally flawed. Justice Viswanathan, who authored the judgment, emphasized that disability assessments should focus on individual capabilities rather than a rigid set of physical requirements.
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"One Size Fits All" Approach is Unacceptable : The Court criticized the rigid application of the eligibility condition and stressed the importance of individual assessments:
"Flexibility in addressing individual needs is essential for reasonable accommodation. A 'one size fits all' approach is untenable."
The ruling reiterated that blanket restrictions like the "both hands intact" condition ignore the core principles of reasonable accommodation and equal opportunity.
The Court ruled that the condition violated Article 41 of the Indian Constitution, which ensures the right to work, education, and public assistance in cases of disability, sickness, and old age. It also contradicted the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), which India has ratified.
"A requirement like 'both hands intact' reeks of ableism and has no place in statutory regulations. It undermines the rights guaranteed under the Constitution and the RPwD Act."
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This ruling significantly changes the way medical aspirants with disabilities will be assessed. The Court directed that:
- Functional assessments must replace blanket physical conditions.
- Assistive technology and accommodations should be considered while evaluating a candidate’s capability.
- The NMC must revise its guidelines to ensure an inclusive medical education system.
The Supreme Court relied on past judgments, including:
- Omkar Ramchandra Gond v. Union of India – Held that the mere quantification of disability should not disqualify a candidate; their functional ability must be assessed.
- Om Rathod v. Director General of Health Services – Stressed the importance of reasonable accommodation for persons with disabilities in medical education.
The Court found that the disability assessment board had failed to provide adequate reasons for denying the appellant admission, violating the precedents set in these cases.
The Supreme Court emphasized the urgent need for revised NMC guidelines that align with its directives. The bench noted that previous judgments had already urged the NMC to reconsider its approach, stating:
"We direct the National Medical Commission to file an affidavit on the status of revised guidelines by March 3, 2025."
The Court insisted that the new guidelines must involve domain experts and representatives from the disability rights community to ensure fairness and inclusivity.
