The Supreme Court has reduced the punishment imposed on senior pediatrician Dr. Nigam Prakash Narain in a case linked to alleged non-disclosure during a Medical Council of India (MCI) inspection process. While the Court noted that there was a lapse in the declaration submitted by the doctor, it held that the penalty of removing his name from the Indian Medical Register for three months should be replaced with a warning.
Background of the Case
Dr. Nigam Prakash Narain, a retired Professor and Head of Pediatrics at Patna Medical College, had briefly joined Shridev Suman Subharti Medical College, Dehradun, after retirement in 2015. Later, he returned to Patna Medical College on a contractual appointment.
The dispute arose after the Medical Council of India conducted inspections at both institutions during the same academic year. The MCI alleged that Dr. Narain had failed to disclose his earlier appearance at the Dehradun medical college while signing a declaration form connected with the Patna Medical College inspection.
Initially, the Ethics Committee found that Dr. Narain was not guilty because he was abroad attending a medical conference in Amsterdam on the day of the Patna inspection. However, the matter was later reconsidered, and the Ethics Committee recommended removal of his name from the Indian Medical Register for three months for “serious misconduct.”
A Single Judge of the Patna High Court had earlier set aside the punishment, observing that Dr. Narain had already resigned from the Dehradun institution before joining Patna Medical College again. The court also noted that there was no intention to simultaneously work at two medical colleges.
However, the Division Bench later restored the punishment. It held that the declaration form signed by Dr. Narain did not disclose his earlier appearance before the MCI inspection team at the Dehradun college during the same academic year.
The bench of Justice Dipankar Datta and Justice Satish Chandra Sharma observed that the original show-cause notice against Dr. Narain was related to allegations of “fake faculty declaration forms.” However, after he successfully explained that he was abroad on the inspection date, the Ethics Committee shifted focus to an alleged omission in the declaration form without issuing a fresh notice.
“The Executive Committee could not have imposed the punishment without issuing a fresh show cause notice and/or without granting Dr. Narain a fair and reasonable opportunity,” the Court observed.
At the same time, the Court also noted that Dr. Narain had failed to satisfactorily explain the incorrect declaration made by him.
The bench said,
“Failure to explain such a brazen mis-declaration, ipso facto, would afford a ground to view such mis-declaration as misconduct.”
Considering that nearly ten years had passed since the 2016 order and that Dr. Narain is now 76 years old, the Supreme Court decided not to uphold the harsher punishment.
Invoking its powers under Article 142 of the Constitution, the Court requested the National Medical Commission to reduce the punishment from removal of his name from the register for three months to issuance of a censure or warning.
The civil appeal was accordingly allowed.
Case Details
Case Title: Dr. Nigam Prakash Narain v. National Medical Commission & Ors.
Case Number: Civil Appeal arising out of SLP (C) No. 22707 of 2023
Judge: Justice Dipankar Datta and Justice Satish Chandra Sharma
Decision Date: May 6, 2026
