Prima facie arbitrariness in medical admission classification justified interim stay despite limited discussion of injunction factors.

Interim stay on a State notification governing weightage and reservation in post-graduate medical admissions was upheld because the record disclosed a prima facie case of arbitrariness and an arguable constitutional challenge to the geographical classification of remote and difficult areas. The challenged scheme also raised a plausible issue whether the notification conferred retrospective benefit on a selected class of doctors. The absence of a detailed discussion on balance of convenience or irreparable injury did not vitiate the interlocutory order where the materials supported the exercise of discretion. No ground was found for appellate interference, and the interim protection granted by the single judge was left undisturbed.

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Issues: Whether the interim stay on the State notification concerning weightage and reservation for post-graduate medical admission was justified on the basis of a prima facie case and whether the challenged classification of remote and difficult areas disclosed any apparent constitutional infirmity warranting interference at the interlocutory stage.

Analysis: The notification was assailed as arbitrary, discriminatory and beyond the State's competence, while the opposite view was that it merely implemented the regulatory framework governing post-graduate medical admissions. The record disclosed a prima facie challenge to the geographical classification adopted for identifying remote and difficult areas, including the inclusion and exclusion of particular districts and institutions, and also raised an arguable question whether the notification gave retrospective benefit to a selected class of doctors. The existence of a prima facie case was sufficient for the interim order, and the absence of a detailed discussion on balance of convenience or irreparable injury did not by itself vitiate the order where the materials on record supported the exercise of discretion.

Conclusion: The interim order was held to be justified, and no ground was found for appellate interference.

Final Conclusion: The appeals were found to lack merit, and the interlocutory protection granted by the learned single Judge was left undisturbed.

Ratio Decidendi: An interlocutory order may be sustained where the record discloses a prima facie case and the challenged action raises an arguable issue of arbitrariness or invalid classification, even if the order does not separately discuss every injunctive factor in detail.

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