Statutory university qualifications need no separate nursing council recognition, and registration must be assessed on merits.

A qualification awarded by a university established under a statute is self-validating and does not require separate recognition by the Indian Nursing Council for registration under the Rajasthan Nurses, Midwives, Health Visitors and Auxiliary Nurse-Midwives Registration Act, 1964. The refusal to register candidates solely because the university was not separately recognised by the Indian Nursing Council was impermissible. Registration must therefore be considered on merits, subject to the applicants' other eligibility requirements, and the Nursing Council was directed to process the applications expeditiously.

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Issues: Whether a degree or diploma obtained from a university established under a statute requires separate recognition from the Indian Nursing Council for registration under the Rajasthan Nurses, Midwives, Health Visitors and Auxiliary Nurse-Midwives Registration Act, 1964.

Analysis: The petitioners completed GNM and ANM courses from a university established under a statute and thereafter sought registration with the Rajasthan Nursing Council. The refusal was based solely on the ground that the university was not recognised by the Indian Nursing Council. The governing principle applied was that a qualification granted by a university created by law is self-validating and does not depend on recognition by another authority. On that basis, the absence of recognition by the Indian Nursing Council could not defeat the petitioners' claim to registration if they were otherwise eligible.

Conclusion: The refusal to register the petitioners on the ground of want of recognition of the university by the Indian Nursing Council was held impermissible, and the petitioners' request for registration was entitled to be considered on merits.

Final Conclusion: The writ petition succeeded and the Nursing Council was directed to process the petitioners' applications for registration expeditiously, subject to their other eligibility.

Ratio Decidendi: A qualification awarded by a university established under a statute is automatically recognized by virtue of the university's legal status and cannot be refused recognition by another authority merely because that authority has not separately recognised the university.

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