PG Medical Student Who Fails One Theory Paper Must Re-Appear In All Four Papers Along With Practical & Viva: Telangana High Court
The Telangana High Court has held that a postgraduate medical student who fails even one theory paper cannot seek permission to re-appear only in that paper, and must instead re-appear for all four theory papers along with practical/clinical and viva voce examinations, in terms of the regulatory scheme governing PG medical education. Referring to the provisions of Post Graduate Medical...
The Telangana High Court has held that a postgraduate medical student who fails even one theory paper cannot seek permission to re-appear only in that paper, and must instead re-appear for all four theory papers along with practical/clinical and viva voce examinations, in terms of the regulatory scheme governing PG medical education.
Referring to the provisions of Post Graduate Medical Education Regulations 2023, Justice Nagesh Bheemapaka observed:
“The regulatory framework, as placed on record, clearly establishes that the Post Graduate medical examination is a composite and integrated assessment consisting of multiple components, namely theory (four papers), practical/clinical and viva voce, and that each of these components constitutes a 'head of passing'… Once a candidate fails to meet the prescribed minimum in any one component, the result is declared as 'failed', and the candidate is required to undergo the process of re-assessment in accordance with the regulatory scheme.”
The Court thus rejected the plea of an M.D. Anesthesiology student who had failed Paper-I by one mark and wanted permission to re-write only that paper.
The petitioner, Salman Mahmood, had completed his three-year postgraduate course in M.D. Anesthesiology at Deccan College of Medical Sciences for the academic period 2022–2025 and appeared for the Post Graduate Medical Examination conducted by the respondent University in October 2025.
The examination consisted of four theory papers—Paper-I Basic Sciences and Applied Anatomy, Paper-II Systemic and Regional Anesthesia, Paper-III Systemic and Super Specialty Anesthesia, and Paper-IV Recent Advances and ICU—besides practical/clinical and viva voce components. When the results were declared in November 2025, he secured 39 marks in Paper-I as against the minimum pass mark of 40, and was therefore declared failed.
Before the Court, the petitioner contended that under Clause 8.4 of the Post-Graduate Medical Education Regulations, 2023, failure in one head does not mean that a candidate must necessarily re-appear in all four theory papers. According to him, the regulation only required re-appearance in the paper in which he had failed, along with practical/clinical and viva voce, and the University was misreading the provision by insisting on a complete re-appearance in all theory papers.
He also relied on an earlier order passed in W.P. No.36837 of 2025, pursuant to which he was allowed to inspect his answer scripts through the Grievance Committee. On such inspection, it was allegedly found that in respect of Question No.6, although he had answered the question, no marks whatsoever had been awarded and there was no indication of evaluation by the examiner. On that basis, he argued that there had been non-consideration of his answer.
The respondent University opposed the petition, contending that the Regulations clearly require a candidate who fails “even under one head” to re-appear for all four theory papers along with practical/clinical and viva voce. It was further submitted that the petitioner's answer scripts had been subjected to the prescribed process of double valuation, and that despite evaluation by two examiners, he had not secured any marks for Question No.6. The University also stressed that no grace marks are permissible in PG examinations and that revaluation is expressly barred.
Accepting the University's stand, the Court held that the relevant provision could not be read in isolation or “in a truncated manner” to suit the petitioner's interpretation. The Bench observed that the PG medical examination is a composite and integrated assessment, and that the requirement is not merely paper-specific but embedded in a larger framework of overall competency across theory, practical/clinical, and viva voce. The expression “fails even under one head”, the Court said, cannot be narrowly construed to mean failure in only a single paper.
The Court also found no merit in the grievance regarding non-award of marks for Question No.6. It held that mere absence of markings or notations on a particular answer cannot by itself lead the Court to infer non-evaluation or undertake a reassessment of the answer. Evaluation of answer scripts, the Court reiterated, lies within the exclusive domain of subject experts, and in matters concerning specialised disciplines such as medical education, the scope of judicial review is “extremely limited.”
Noting further that the petitioner had not challenged the validity of the Post-Graduate Medical Education Regulations, 2023, the Court held that he could not seek a direction contrary to the express regulatory scheme.
Finding no arbitrariness, illegality, or violation of Article 14 in the action of the University, the Court dismissed the writ petition.
Case Title: Salman Mahmood v. State of Telangana & others
Case No.: Writ Petition No.6560 of 2026
Appearance: Ms. P. Krishna Keertana for the petitioner; Government Pleader for Medical, Health and Family Welfare; Sri T. Sharath, Standing Counsel for the respondent University.