Authority: High Court of Odisha, Cuttack

Order Date: 04 November 2026

Case Overview

  • Petition under Articles 226 & 227 of the Constitution filed by Dr. Anwesha Panda against the State of Odisha and others, seeking quash of posting order dated 17‑Jan‑2026 and Notification No.1031 dated 09‑Jul‑2026, and directing issuance of permanent registration.
  • Dr. Panda obtained her MBBS‑equivalent MD (General Medicine) from S. Tentishev Asian Medical Institute, Kyrgyzstan, admission on 31‑Oct‑2017, course completion on 04‑Jul‑2023, with a certificate dated 05‑Jun‑2023.
  • Due to COVID‑19, she stayed in India from 22‑Jul‑2020 to 13‑Nov‑2021 (15 months 21 days) and compensated missed online classes by attending physical classes for 9 months 10 days (14‑Nov‑2021 to 05‑Jul‑2022 and 15‑Sep‑2022 to 05‑Nov‑2022).
  • She cleared the National Board of Examinations screening test (Pass Certificate dated 23‑Sep‑2025) and received provisional registration from the Odisha Council of Medical Registration (OCMR) on 07‑Jan‑2026.
  • The impugned order (17‑Jan‑2026) directed her to undergo a two‑year internship: one year clerkship plus one year Compulsory Rotatory Medical Internship (CRMI) under the CRMI Regulations, 2021.
  • The petitioner argued that Regulation 5(1)(b) of the CRMI Regulations exempts candidates who began their foreign medical education before the regulation’s commencement (18‑Nov‑2021), and therefore the additional CRMI year is inapplicable.
  • Opposing parties contended that after deducting a 4‑month vacation, the net deficit of physical class attendance was 2 months 11 days, exceeding the 30‑day condonable limit, justifying the two‑year internship.
  • The Court examined the Institute’s certificate, the screening test pass, the provisional registration, and the comparative cases of Dr. Arabinda Mohapatra and Dr. Rajat Kumar Nayak, where deficits of ≤30 days were condoned.
  • The Court noted that the petitioner’s compensated physical attendance (9 months 10 days) was documented, and the calculated shortfall of 2 months 11 days was therefore unfounded.
  • It held that the CRMI Regulation 2021 does not apply to the petitioner because her MD program commenced in 2017, prior to the regulation’s effective date, per Regulation 5(1)(b).
  • Consequently, the requirement to undergo the additional CRMI year is not tenable.

Final Outcome

  • The Court interferes with the 17‑Jan‑2026 order, reducing the internship requirement to one year (clerkship only).
  • It directs the Odisha Council of Medical Registration and the other opposite parties to allow Dr. Anwesha Panda to complete a single‑year internship.
  • The writ petition is disposed of.

Topics: Medical Licensing, Judicial Review