Rajasthan High Court Directs Admission Of NEET-PG Candidate Denied For Want Of Permanent Registration Certificate
The Rajasthan High Court granted relief to a doctor who was denied admission in the college allotted through NEET-PG 2025, on the ground of not possessing the original Permanent Registration Certificate issued by the Chhattisgarh Medical Council, in light of Clause 4.6 of the NEET-PG 2025 Information Bulletin. While making a reference to Regulation 8(3) of the Post Graduate Medical...
The Rajasthan High Court granted relief to a doctor who was denied admission in the college allotted through NEET-PG 2025, on the ground of not possessing the original Permanent Registration Certificate issued by the Chhattisgarh Medical Council, in light of Clause 4.6 of the NEET-PG 2025 Information Bulletin.
While making a reference to Regulation 8(3) of the Post Graduate Medical Education Regulations, 2000 (PGM 2000) that grants one month period after admission to obtain such registration, the bench of Dr. Justice Nupur Bhati held that administrative/executive instruction/information bulletins could not override statutory regulations.
After completing her MBBS, the Petitioner obtained Provisional Registration from Chhattisgarh Medical Council. For obtaining permanent registration, she joined the mandatory two years State service and meanwhile also appeared for NEET-PG 2025.
Through NEET-PG 2025, she was allotted a college. However, when she reported to the allotted college, she was denied admission on the ground that she did not possess the original permanent registration certificate. Hence, the appeal was preferred.
The petitioner made a reference to the Regulation 8(3) of PGM 2000 and held that it mandated one month after the date of admission for obtaining the permanent registration certificate.
On the contrary, the State referred to the NEET-PG 2025 information bulletin that required the candidate to have the requisite document at the time of seeking admission.
After hearing the contentions, the Court referred to Clause 4.1 of Chapter IV of the National Medical Commission Notification dated December 29, 2023, that provided that until the National Exit Test (NEXT) was implemented, admissions to postgraduate medical courses shall be governed by PGM 2000.
This was read with Regulation 8(3) of the PGM 2000, and the Court opined that the statutory scheme did not mandate possession of permanent registration certificate as an inflexible precondition at the time of reporting or admission. Such registration was required within one month.
“This reflects a purposive legislative intent aimed at preventing undue hardship to the meritorious candidates, who may be in the process of obtaining permanent registration at the relevant point of time…action of the respondents in denying admission to the petitioner solely on the ground of non-production of the Permanent Registration Certificate at the time of reporting is arbitrary, and in direct contravention of Regulation 8 (3) of the Regulations of 2000, as well as the governing framework under the NMC notification Dated 29.12.2023.”
It was held that once the statutory regulations expressly permitted a candidate to obtain registration within one month, State could not have curtailed such right by imposing more onerous condition through an information bulletin. Such act defeated the object and purpose of regulations.
In this background, State's actions were held to be unsustainable in the eyes of law, and it was directed to grant admission to the petitioner.
Title: Dr. Parnika Sharma v State of Rajasthan & Ors.
Citation: 2026 LiveLaw (Raj) 118