Merit-based postgraduate medical admissions prevail; courts should not override duly framed selection rules absent arbitrariness.

Postgraduate medical admissions may be regulated strictly on academic merit where government orders and duly framed Medical Council rules prescribe merit-based selection and eligibility standards. Those norms are enforceable because they are intended to preserve educational standards and prevent admissions on extraneous considerations. Where the academic authority applies the rules bona fide and uniformly, the High Court should not substitute a different selection criterion, relax merit requirements, or direct admission contrary to the governing rules. Mandamus cannot be issued in disregard of the prescribed admission framework; judicial interference is justified only where arbitrariness, prejudice, or bias is shown.

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Issues: (i) Whether admission to the postgraduate medical courses could be regulated strictly on the basis of academic merit under the Government order and the Medical Council rules. (ii) Whether the High Court could interfere with the academic body's selection and direct admission contrary to the prescribed merit criteria.

Issue (i): Whether admission to the postgraduate medical courses could be regulated strictly on the basis of academic merit under the Government order and the Medical Council rules.

Analysis: The admission policy required selection only on merit, measured by performance in the MBBS examination and allied assessment criteria. The Medical Council rules, framed under the statutory power, also emphasized selection on academic merit and prescribed training and eligibility standards for postgraduate medical education. The Court held that these norms were designed to preserve standards in medical education and to prevent admissions based on extraneous considerations.

Conclusion: Admission could validly be regulated strictly on the basis of academic merit, and the prescribed rules were binding and enforceable.

Issue (ii): Whether the High Court could interfere with the academic body's selection and direct admission contrary to the prescribed merit criteria.

Analysis: Where the academic authority had applied the rules bona fide and uniformly, the High Court was not entitled to substitute its own criterion or relax the requirements. A candidate with lower merit could not be admitted merely because of a diploma or because the Court considered the candidate otherwise suitable. The Court also held that the extraordinary relief of mandamus could not be granted beyond the prayer or in disregard of the governing rules.

Conclusion: The High Court could not override the academic body's merit-based decision, and the mandamus directing admission in the concerned case was unsustainable.

Final Conclusion: The appeals were disposed of on a mixed basis, with some admissions and result-declarations maintained by concession, while the High Court's interference was rejected in the case where it had overridden the merit rule.

Ratio Decidendi: In postgraduate medical admissions, statutory and duly framed academic rules prescribing merit-based selection are binding, and constitutional courts should not substitute their own criteria or direct admission contrary to those rules absent demonstrable arbitrariness, prejudice, or bias.

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