Essentiality certificate for medical colleges: State has a limited role in site feasibility, while final approval stays with central authorities.

The State Government has a real but limited role in granting an essentiality certificate for a proposed medical or dental college, including consideration of local needs, public interest, feasibility, and availability of clinical material. That role extends to the desirability and feasibility of the proposed location, but final approval remains with the Medical Council, Dental Council, and Central Government under the statutory scheme. The State must act reasonably on relevant considerations and with cogent reasons, and cannot act arbitrarily or capriciously. Article 371D does not govern site identification for this purpose, and the contrary view that the State had no role in identifying sites was rejected.

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Issues: Whether the State Government has a role in identifying the location of a proposed medical or dental college while granting an essentiality certificate, and whether its decision in that regard is final or must yield to the Medical Council, Dental Council, and Central Government under the governing statutory scheme.

Analysis: The scheme under the Medical Council of India Act and the corresponding regulations requires an essentiality certificate from the State Government as part of the application process for setting up a medical college. The prescribed form obliges the State to consider matters such as local needs, public interest, feasibility, and availability of adequate clinical material. That statutory role is a limited one, but it is real and substantive. The State is not exercising a final power to approve the college, because the Medical Council and the Central Government retain the ultimate function of recommendation and permission. Even so, the State cannot be treated as having no say on location, nor can it be confined to a purely mechanical function. The Court held that the High Court erred in ruling that the State had no role in identifying sites. At the same time, the State must act reasonably, on relevant considerations, and with cogent reasons, and cannot act arbitrarily or capriciously. Article 371D does not govern the identification of sites for this purpose.

Conclusion: The State Government has a positive but limited role in deciding the desirability and feasibility of the proposed location while granting an essentiality certificate, but the final permission remains with the Central statutory authorities. The contrary view of the High Court was rejected, and the connected matters were sent back for fresh consideration according to law.

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