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Issues: (i) whether a candidate who had not claimed backward-area reservation in the application form and had not filed the required certificate within time could be admitted against a subsequently vacant reserved seat on compassionate ground, and whether an additional seat could be created for another candidate; (ii) whether the statutory limit on admission capacity in dental institutions could be overridden by judicial direction.
Issue (i): whether a candidate who had not claimed backward-area reservation in the application form and had not filed the required certificate within time could be admitted against a subsequently vacant reserved seat on compassionate ground, and whether an additional seat could be created for another candidate.
Analysis: Admission to professional courses must conform to the prescribed eligibility conditions and the merit-cum-reservation scheme. A claim to a reserved seat cannot be entertained when no such claim was made in the application and the supporting certificate was not filed within the prescribed time. The candidate who had applied in proper form with the required certificate had the better claim to the vacant reserved seat. A direction to create an additional seat was not warranted.
Conclusion: The direction admitting the first respondent against the vacant seat was set aside, and the second respondent was held entitled to be admitted against that vacant seat. The direction to create an additional seat did not survive.
Issue (ii): whether the statutory limit on admission capacity in dental institutions could be overridden by judicial direction.
Analysis: The Dentists Act regulates admission capacity in dental colleges and permits increase in intake only with previous permission of the Central Government. Judicial orders cannot compel authorities to violate the statutory ceiling fixed on the basis of infrastructure, staff and related requirements. A direction to create a seat without such permission would defeat the statutory scheme.
Conclusion: The order creating an additional seat was contrary to the statutory framework and could not be sustained.
Final Conclusion: The appeals succeeded in part by restoring the statutory admission scheme, substituting the proper claimant for the reserved vacancy, and rejecting the direction to expand intake beyond the sanctioned capacity.
Ratio Decidendi: Courts cannot direct admission in disregard of statutory eligibility requirements or compel creation of additional seats in professional courses where intake capacity is fixed by law and can be increased only with the requisite governmental permission.