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Issues: Whether the Medical Council's regulation prescribing minimum qualifying marks for admission to medical colleges was mandatory or merely directory, and whether the State Government's executive order completely relaxing those marks for Scheduled Castes and Scheduled Tribes candidates was invalid under the Constitution.
Analysis: The scheme of the Indian Medical Council Act, 1956 shows that the Council's statutory function is to maintain standards of medical education and to prescribe the minimum educational eligibility for admission to the medical course. The regulation dealing with admission eligibility is mandatory, but the regulation dealing with selection from among eligible candidates is only a recommendation and not an enforceable statutory command. Selection of candidates among those already eligible is a matter that may depend on local conditions and falls within the State's executive power where no law occupies the field. The State's order did not relax the eligibility standard for admission; it relaxed the selection criterion only for reserved seats so that the reservation for Scheduled Castes and Scheduled Tribes would operate effectively. Such relaxation was held to be permissible under the constitutional power to make special provision for these classes and did not amount to hostile discrimination.
Conclusion: The regulation governing selection was held to be directory, not mandatory, and the State Government's order was upheld as valid and constitutional.
Final Conclusion: The impugned High Court judgment was set aside, the writ petition was dismissed, and the State's executive relaxation for reserved-category medical admissions was sustained.
Ratio Decidendi: A statutory or regulatory prescription governing selection among already eligible candidates may be treated as directory where the parent enactment does not confer authority to regulate that selection field, and a State may, in the absence of contrary law, relax selection conditions for reserved seats to give effective operation to constitutionally permitted reservations without violating equality guarantees.