Dental Masters Must Be Completed Within 6 Yrs; Mere Demand Draft Without Formal Request Letter Can't Secure Readmission: AP High Court
The Andhra Pradesh High Court has held that a Demand Draft submitted by a Master of Dental Surgery (M.D.S.) student, without enclosing a formal “request letter”, could not be treated as a request for continuation of the course.
While doing so, the Court dismissed a plea by an M.D.S. student seeking permission to continue his course beyond the maximum six-year period.
The Court took note of the petitioner's deficient attendance and his failure to regularly attend classes and clear the requisite examinations within the stipulated period.
Regulation 11(1) of the Master of Dental Surgery Course Regulations, 2017 prescribes a three-year M.D.S. course and provides that a candidate must complete the course within a maximum period of six years from the date of admission.
Before Chief Justice Lisa Gill and Justice Challa Gunaranjan was a writ petition filed by a postgraduate dental student seeking to set aside the communication of Dr. NTR University of Health Sciences rejecting his request to continue his M.D.S. course and to direct the University to permit him to pursue the course.
The Court observed:
“A perusal of writ affidavit and material on record reveals that while drawing Demand Draft dated 07.03.2023, petitioner did not enclose any formal “request letter”. Petitioner claims that he was not aware of the procedure to avail of an opportunity to continue with the P.G.Course, and thus had not addressed any letter enclosing Annexures 1 & 2, which could have been done only after respondent No.3 College apprised him. Argument as raised before us and noted in para 9 above, is in direct contradiction to specific pleadings. Respondent University, in its counter-affidavit, has specifically stated that no application was received prior to 27.06.2024.
Be that as it may, it is to be noticed that even if Demand Draft dated 07.03.2023 is considered as a request, which in effect is not possible, petitioner by no stretch of imagination can complete the course within a period of six years from the date of his admission. His eligibility qua attendance, etc., is also clearly deficient.”
The petitioner had completed his Bachelor of Dental Surgery (B.D.S.) course during 2012-2017 and joined the respondent college in 2018 for the three-year Master of Dental Surgery (M.D.S.) course.
However, he could not initially clear his first-year Basic Sciences paper and eventually cleared the examination in 2021 after five attempts. Due to the backlog, he could not appear for the third-year examinations.
Thereafter, during 2022, the petitioner could not attend his daily classes, though he attended some postings, presentations and seminars in 2023. Subsequently, he was not permitted to attend postings on the ground that he did not have the requisite attendance.
The petitioner was then advised by the college to seek readmission/continuation of the M.D.S. course and submitted a Demand Draft in March 2023. As he received no response, he submitted a representation in June 2024 along with another Demand Draft.
The University, however, vide its impugned communication, rejected his request on the ground that the maximum six-year period for completing the course had already expired in May 2024.
Aggrieved by the rejection, the petitioner challenged the same before the High Court.
The petitioner contended that the six-year period would expire only in May 2024 and, therefore, rejection of his request was unjustified. He submitted that he had deposited the requisite fees and could not complete his studies due to an ailment. He also argued that the Demand Draft submitted in March 2023 itself should be treated as a “request for continuation of the course”.
The University, on the other hand, relied on Regulation 11.1 to submit that the M.D.S. course had to be completed within six years of admission. It contended that the petitioner's attendance had fallen from 84% and 87% in the first two academic years to 39% in 2020-21 and 4% from June 2022 to May 2023. He did not attend any classes from June 2023 to November 2024.
The University further maintained that it had received no application from the petitioner before June 2024, while the respondent college stated that the petitioner approached it for re-admission only in June 2024.
The plea was dismissed.
Case Title: Dr. U. Anudeep v. Dr. N.T.R. University of Health Sciences & Ors.
Case No.: W.P. No. 13043 of 2025
Counsel for the Petitioner: Chukka Kranthi Kiran
Counsel for the Respondents: C. V. R. Rudra Prasad and Tata Venkata Sridevi