In a significant judgment promoting the principles of inclusion, accessibility, and reasonable accommodation, the Supreme Court of India on April 8, 2025, directed the All India Institute of Medical Sciences (AIIMS) to constitute a specialized five-member medical board to reassess the disability of a Scheduled Caste/PwBD candidate, Kabir Paharia, who had excelled in the NEET UG 2024 examination but was denied admission based on the National Medical Commission (NMC)‘s controversial guidelines.
Background of the Case
The petitioner, Kabir Paharia, was born with a congenital absence of multiple fingers on both hands and had partial involvement of his left foot. Despite these challenges, he achieved an impressive category rank of 176 in NEET 2024 under the SC/PwBD quota. However, when he approached the concerned medical authorities for a disability certificate, his application was rejected under existing NMC guidelines, which require candidates to have “both hands intact, with intact sensation and sufficient strength” for MBBS admission.
The Supreme Court bench comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta took strong exception to this rigid application of medical guidelines and invoked the ratio decidendi of two recent landmark rulings—Om Rathod v. DGHS (2024) and Anmol v. Union of India & Ors (2025)—which declared the NMC’s blanket exclusionary criteria to be arbitrary, discriminatory, and unconstitutional.
Legal Developments: Om Rathod & Anmol Judgments
In Om Rathod, the Supreme Court held that the mere existence of a benchmark disability should not be an automatic disqualifier for MBBS admission. The judgment emphasized the need for individual assessment to determine if the disability would prevent the candidate from successfully pursuing the medical course. The medical board must evaluate functional limitations in the context of technological aids, assistive devices, and reasonable accommodations.
In *Anmol, the Court struck down NMC guidelines that mandated “both hands intact” for MBBS eligibility, holding such stipulations as violative of Articles 14 and 21 of the Constitution. The Court reiterated that reasonable accommodation is integral to ensuring equality of opportunity for persons with disabilities, in line with the Rights of Persons with Disabilities Act, 2016 and the principles of UNCRPD (United Nations Convention on the Rights of Persons with Disabilities).
Supreme Court’s Observations in Kabir Paharia’s Case
The Supreme Court noted that the petitioner’s outstanding academic performance and high merit rank in the NEET examination warranted a reassessment of his eligibility under the lens of the evolving jurisprudence on disability rights.
The Court categorically rejected the NMC’s submission that it was in the process of updating its guidelines and that relief should be withheld until the new norms were notified. The bench observed:
“Merely because the NMC is under the process of revising the guidelines, the petitioner’s fate cannot be allowed to hang in limbo.”
The Court held that to deny the petitioner admission at this stage, especially after he had cleared NEET with distinction, would amount to a grave miscarriage of justice and a violation of his fundamental rights under Articles 14, 19, and 21.
Constitution of a Specialized Medical Board at AIIMS
To ensure impartiality and expertise in evaluating Kabir’s disability, the Supreme Court directed the constitution of a new Medical Board at AIIMS, New Delhi, comprising five doctors. Importantly, it mandated that the board must include:
- One specialist in locomotor disabilities
- One neuro-physician
The Board has been ordered to submit its report in a sealed cover by April 15, 2025.
Advocate Rahul Bajaj’s Submissions
Appearing for the petitioner, Advocate Rahul Bajaj highlighted how both the medical boards previously constituted by the Delhi High Court had failed to consider essential elements such as:
- The candidate’s academic excellence
- His high placement in merit
- Availability and usage of assistive technologies
- The principle of reasonable accommodation
He emphasized that the petitioner was in a better functional position than the candidates in Om Rathod and Anmol, both of whom were ultimately granted MBBS admission after individualized assessment.
Broader Implications for Disability Rights in Education
This judgment reinforces the transformative nature of the Constitution, especially with regard to disabled students’ rights to equal education opportunities. It aligns with India’s obligations under the RPwD Act, 2016, which mandates that persons with disabilities must not be discriminated against in higher education and must be provided reasonable accommodation.
It also sends a clear message to regulatory bodies like the NMC that outdated and exclusionary policies will not withstand judicial scrutiny. The Court’s directive compels NMC to adopt a more human rights-based and individual-centric approach when formulating eligibility criteria.
Conclusion
The Supreme Court’s intervention in Kabir Paharia v. National Medical Commission & Ors marks another vital step in dismantling systemic barriers faced by disabled students in accessing professional education, particularly in medical courses. It emphasizes that merit should be measured by intellect and dedication, not by the presence of limbs.
This case, along with Om Rathod and Anmol, contributes to a growing jurisprudence that upholds the dignity, capability, and potential of persons with disabilities. As India marches towards a more inclusive and equitable educational framework, this judgment will undoubtedly serve as a legal precedent for future cases involving disability, education rights, and constitutional equality.
