Authority: High Court of Chhattisgarh at Bilaspur

Order Date: 17 July 2026

Case Overview

  • Petitioner: Shri Rawatpura Sarkar Institute of Medical Sciences and Research, a private unaided medical college established under Shri Rawatpura Sarkar Lok Kalyan Trust.
  • Respondents: State of Chhattisgarh (Dept. of Health & Family Welfare & Medical Education), Director, Directorate of Medical Education, Pt. Deendayal Upadhyay Memorial Health Sciences and Ayush University, and National Medical Commission of India.
  • Petition sought enhancement of undergraduate MBBS seats from the existing 100 to 250 for Academic Year 2026‑27 (an increase of 150 seats) under Article 226 of the Constitution.
  • The Directorate of Medical Education (Respondent 2) issued an Essentiality Certificate dated 03‑02‑2026 approving only 50 additional seats, limiting total intake to 150; the University (Respondent 3) issued a corresponding Consent of Affiliation on the same date.
  • Inspection chronology: initial inspection on 16‑01‑2026, deficiency notice on 24‑01‑2026, petitioner’s reply on 29‑01‑2026, re‑inspection on 02‑02‑2026. Inspection reports were never furnished to the petitioner.
  • Respondent 2 argued that a 22% shortage of teaching faculty existed and that the petitioner’s application violated Regulation 13, which permits a maximum increase of 100 seats in a single application.
  • Petitioner contended that the deficiency reports were not shared, denying a fair hearing, and that the institution complied with all infrastructure and faculty norms.
  • The Court examined the statutory framework (Establishment of New Medical Institutions, Assessment and Rating Regulations 2023), the requirement that institutions must maintain prescribed faculty strength, and the prohibition on “work‑in‑progress” applications.
  • The Court found that the petitioner’s application was non‑compliant with the 100‑seat limit, that the faculty shortage was substantive and persisted after re‑inspection, and that the State’s procedure complied with natural‑justice requirements.

Final Outcome

  • The writ petition is dismissed in its entirety.
  • No order as to costs.
  • The State’s Essentiality Certificate granting only 50 additional seats and the University’s Consent of Affiliation are upheld.

Topics: Medical Education, Seat Allocation