Friday, January 30, 2015

Unrecognized Medical Degree / Diploma; Employment, Promotion A Review of Indian Court’s Judgments

Dr. Mukesh Yadav, B. Sc., M.B.B.S., M.D., LL.B., PGDHR, MBA (HCA)
Director/Principal/Dean & Professor, Forensic Medicine & Toxicology
Siddhant School of Medical Sciences, Mainpuri, U.P.
Medical education is the subject matter of both Union and State Governments and Medical Council of India is the sole supervising body of medical education and maintaining its standard. Problem of recognition of medical degrees / diplomas is prevalent in almost all the States of India and in most of the medical specialties. Holders of unrecognized degree / diploma may face problem of employment / promotion, etc. thus leading to many litigations either decided or pending in the Indian Courts.
This paper deals with review of this problem, brief discussion of relevant court decisions, Government Orders and MCI notifications, etc. thus help in solving this problem to great extent by making concerned persons aware about the issue and to take initiative to solve the problem of very much public interest.
Key Words: Unrecognized Medical Degree / Diploma, Employment, Promotion, Medical Council of India, Court.
The problem of recognition of degree / diploma and employment is not new issue as apparent from various courts’ decisions and other relevant documents of Government and Medical Council of India. Since medical education is still in infancy in India as private medical colleges are mushrooming and as India is a developing economy many problems are bound to arise. This problem is prevailing in many States of India like Jammu & Kashmir, Himanchal Pradesh, Punjab, Haryana, U.P., Bihar, Tamil Nadu, Delhi etc.
Author himself had received an interview call from the PGIMER, Chandigarh, for the post of Assistant Professor scheduled to be held on 06-12-2005, and concerned authority has asked for certificate from MCI in this regard as a condition to appear before the interview board. Similar is the position with the Union Public Service Commission (UPSC), New Delhi, which asks for letter of recognition of degree issued by the MCI before they allow appearing for the interview.
In a very interesting case in which a doctor holder of M.D. (Pathology) awarded by M.L.B. Medical College, which is not recognized by the MCI. He was given appointment as Senior Lecturer at G.M.C. Medical College, Chandigarh on adhoc basis and continues his job for more than five years till he received a call of interview for the same post on permanent basis through UPSC, New Delhi. But unfortunately his candidature was rejected by the UPSC, after allowing him to appear for the interview.
In an another more interesting case from Allahabad, U.P., one doctor holder of Diploma Cardiology from G.S.V.M. Medical College, which is not recognized by the MCI, faced criminal charges and remain in prison for few months not under section 304-A, but under charges of ‘culpable homicide not amounting to murder for the death of one of his serious patient, for no fault of him, but to hold unrecognized diploma awarded by a Government Medical College of U.P.   
Problem of employment / promotion and possession of unrecognized degree / diploma:
“For the fault of the University, the students cannot be made to suffer. Since they have acquired qualification, degree in M.D. (Pathology and Microbiology) should be amended as the Schedule to Act of 1956, does not recognize the degree in M.D. (Pathology and Microbiology)”; [R-9]
“Where the Post-graduate course was started by the Ranchi University with the consent of Medical Council of India and the State of Bihar had recognized such degree imparted by the Ranchi University, held, it could not be contended that degree obtained after pursuing said course was of no value as the same had not been recognized so far by the Medical Council of India”, [R-8]
Judges, J.S. Khehar and Rajiv Bhalla of Punjab and Haryana High Court while delivering judgment on the issue of recognition of degree and problem of promotion on 09-02-2005.
“The fourth contention of the learned counsel (page No. 20-23) for the respondent is that the petitioner has no locus standi to impugn the selection and promotion of respondent No. 3 Dr. S.S. Sangwan to the post of Dean (Medical) as the petitioner himself is ineligible for appointment by promotion to the aforesaid post under the 1988 Rules. In this behalf, the petitioner acquired the qualification of M.D. (Forensic Medicine) from the Medical College, Rohtak, and that he was awarded the aforesaid Postgraduate Degree, by the Maharishi Dayanand University, Rohtak. In this behalf, it is pointed out, that the qualification of M.D. (Forensic Medicine) awarded by the Maharishi Dayanand University, Rohtak, has not been recognized by the Medical Council of India. It is, therefore, asserted that the petitioner does not even fulfil the basic qualifications for the post of Dean (Medical). [Page No. 21-23]
So far as the fourth contention advanced on behalf of the respondent is concerned, reference will have to be made to the qualifications prescribed for appointment to the post of the Dean (Medical), in Appendix ‘B’ of the 1988 Rules (details wherof have already been extracted above). The essential minimum qualifications for appointment to the post of Dean (Medical) comprise of three essential ingredients. Firstly, a basic University qualification included in the schedule to the Indian Medical Counsel Act, 1956, Secondly, M.D./M.S. or equivalent Postgraduate qualification, and thirdly, five years teaching experience as Professor (Medical). The fact that the petitioner possesses the first and third essential eligibility conditions is not disputed. The only issue which arises for determination is, whether the qualification of M.D. (Forensic Medicine) acquired by the petitioner in 1980 satisfies the second requirement in Appendix ‘B’ of the 1988 Rules, noticed above. In our view, the qualification of M.D. (Forensic Medicine) possessed by the petitioner has to be accepted as relevant qualification for satisfying the second requirement. Our aforesaid conclusion is based on firstly, on the fact that the qualification of M.D. / M.S. or equivalent postgraduate depicted as an essential qualification for appointment to the post of Dean (Medical), is a requirement in the verbatim, even for appointment to the post of Professor (Medical). The petitioner was appointed as Professor in the Institute of Medical Sciences as far back as on 1-06-1981. at the aforesaid juncture, the qualification possessed by the petitioner, was considered to be sufficient for appointment to the post of Professor. It is not open to the respondent at this juncture to assert, that the same postgraduate qualification, which was accepted to determine the eligibility of the petitioner for appointment to the post of Professor, is not acceptable for determining his eligibility for promotion to the post of Dean (Medical). Secondly, while Appendix ‘B’ of the 1988 Rules expressly indicates, that the basic University qualification possessed by an incumbent must be one of the qualifications included in the schedule to the Indian Medical Council Act, 1956, there is no such prescription / requirement in so far as the M.D. / M.S. qualification is concerned. It is, therefore, misconceived for the respondents to assert, that only such M.D. / M.S. qualifications are to be considered as valid for the purposes of eligibility as have been recognized by the Medical Council of India. Thirdly, the petitioner acquired the qualification of M.D. (Forensic Medicine) from the Medical College, Rohtak i.e. the very institute, wherein he is claiming appointment by promotion to the post of Dean (Medical). It is difficult to accept, that the respondent would not accept the postgraduate qualification acquired from the institute itself, as a valid postgraduate qualification for appointment to the post of Dean (Medical). In fact, it would be pertinent to mention, that the official respondents in the instant writ petition did not dispute the eligibility of the petitioner for appointment by promotion to the post of Dean (Medical). The instant objection was raised only at the hands of respondent No. 3. In view of the deliberations recorded above, it is not possible for us to accept even the fourth contention (advanced by the learned counsel representing respondent No. 3) [Page No. 23]
Since the procedure adopted while short listing respondent No. 3 for appointment by promotion to the post of Dean (Medical), was in clear violation of the mandate of Rules 9 (2) of the 1988 Rules, we are satisfied, that the selection and promotion of respondent No. 3 Dr. S.S. Sangwan to the post of Dean (Medical), deserves to be set aside. The same is, accordingly, be immediately relieved from the post of Dean (Medical). [Page No. 26]
The respondent shall reconvene the process of appointment by promotion to the post of Dean (Medical) forthwith. The entire deliberations shall be completed within one month from today, by following the principle of seniority-cum-merit, envisaged under Rule 9(2) of the 1988 Rules. [Page No. 26] writ is disposed of in the aforesaid terms. [Page No. 26] [R-1]

The problem of recognition of degree and employment is not new issue as apparent from this letter: Letter written by the Secretary, U.P., Sri G.K. Joshi, to all Heads of Departments and Principal, Heads of Offices, Niukti (Kha), Vibhag. The contents of letter are as follows:
“Subject: Recognition of the degrees and diplomas awarded by the Universities established by law in India for purposes of recruitment to services under the State Government.
I am directed to say that the question of recognition of the degree / diploma awarded by the Universities as established by law in India for purposes of recruitment to services and posts under the State Government has been under their consideration for some time past. In the light of the decision taken by the Government of India and in consultation with the Lok Seva Ayog, Uttar Pradesh [UPPSC] it has been decided that in the case of degree / diploma awarded by Universities in India which are incorporated by an Act of the Central or State Legislature, no formal orders recognizing such degrees / diplomas need be issued by Government. Such degrees / diplomas should be recognized automatically for purposes of employment under the State Government. [R-2]
In a case from Rajasthan Court observed that--Rajasthan University Ordinance – Ordinance 65 (vii) – Post-graduate medical degree granted by a University duly established by statute in this country which has also recognized by the Indian Medical Council – Ipso facto to be regarded, accepted and treated as valid throughout our country – In absence of any express provision to the country, such a degree does not require to be specifically recognized by other Universities in any State in country before it can be accepted as a valid qualification for the purpose of appointment to any post in such a State be accepted as a valid qualification for the purpose of appointment to any post in such a State. [R-7]
Bench of Justices A.D. Koshal, J., R.B. Mishra,J., V. Balakrishnana Eradi. The judgment of the Court was delivered by Eradi, J.
On March 3, 1972, the Rajasthan Public Service Commission (for short, ‘the Commission’) issued advertisements inviting applications for the recruitment of two Lecturers in Forensic Medicine for Medical College, Medical & Public Health Department in accordance with the Rules. [Para 5]
The appellant had, by then, obtained the M.D. degree in Forensic Medicine from the University of Bihar, Muzaffarpur in1970 and had been functioning as Lecturer in Forensic Medicine in one of the Government Medical Colleges in Rajasthan on a temporary and adhoc basis from December 31, 1970 onwards.   [Para 6]
In response to the aforesaid advertisement published by the Commission, the appellant applied for appointment to one of the posts. However, by the impugned letter (Annexure IV) dated July 21, 1973, issued by the Secretary of the Commission, the appellant was informed that his application for the post of Lecturers in Forensic Medicine was rejected since he did not possess the necessary academic qualification. A representation made by the appellant to the Public Service Commission for reconsideration of the matter did not meet with any favourable response and hence the appellant approached the High Court by filing the writ petition under Article 226 of the Constitution out of which this appeal has arisen. During the pendency of the writ petition, the Commission conducted the interview of the remaining candidates and selected respondents 3 and 4 for appointment to the two posts and on the basis of the said selection the State Government appointed respondents 3 and 4 as Lecturers. The appellant thereupon amended the writ or direction canceling the interview and selection conducted by the Commission as well as the consequential appointments given by the State Government to respondents 3 and 4 as Lecturers in Forensic Medicine. [Para 7]
The appellant is admittedly the holder of the basic degree of M.B.B.S. from the Rajasthan University, which is a qualification entered in the First Schedule to the Indian Medical Council Act. It is also not in dispute that he is duly registered under the Medical Registration Act. The sole ground on which the appellant was treated by the Commission as ineligible for consideration was that the post-graduate degree in Forensic Medicine possessed by the appellant is not one awarded by the University of Rajasthan and the said degree has also not been recognized by the University of Rajasthan as an equivalent qualification. [Para 10]
The University of Bihar at Muzzafarpur is one duly established by statute and is fully competent to conduct examinations and award degrees. The degree of Doctor of Medicine (Forensic Medicine) M.D.   (Forensic Medicine) of The University of Bihar is included in the Schedule to the Indian Medical Council Act, 1956 as a degree fully recognized by the Indian Medical Council which is the parmount professional body set up by statute with authority to recognize the medical qualifications granted by any University or Medical Institution in India. [Para 11]
The conclusion that emerges from the aforesaid dissuasion is that the appellant was fully qualified for being considered for appointment to the two posts of Lecturer in Forensic Medicine advertised by the Commission on November 16, 1972, and that the Commission acted illegally in treating the appellant as not being possessed of the requisite academic qualification and excluding him from consideration on the said ground. [Para 13]
Accordingly, we allow this appeal, set aside the judgment of the Division Bench of the High Court and restore the judgment of the Single Judge, subject to the modification that in carrying out the directions contained in the judgment of the learned Single Judge, the Commission should treat the appellant as a fully qualified candidate in the light of the finding recorded by us that at the relevant time the appellant possessed not merely the prescribed academic qualification but also the requisite experience of two year’s medicolegal work. The appellant will get his costs throughout from respondents 1 and 2 in equal shares. [Para 14] [R-7]
A Bench of Justices N.M. Kasliwal, J. and M.M. Punchi, J. delivered the judgment on April 26, 1991. [R-8]
The controversy has been raised before us that the M. Ch. Degree course in Neuro Surgery awarded by Rajendra Medical College, Ranch University is not yet recognized for the purpose of Indian Medical Council Act, 1956 and a letter of Medical Council of India dated 27-02-1991 has been placed on record in this regard. Learned counsel for the respondent No. 5 has tried to contend that M. Ch. degree obtained by the appellant was of no value, as the same has not been recognized so far by the Medical Council of India. We find no force in this contention, as this course was started by the Ranch University in 1980 with the consent of the Medical Council of India and the State of Bihar has recognized such degree imparted by the Ranchi University and even before this Court learned counsel appearing for the State of Bihar accepted this position. We are not concerned in this case about the value of such degree for places outside State of Bihar, but so far the present case is concerned which relates to the post of Assistant Professor in Patna Medical College and Hospital, Patna which post is under the Bihar Government, no such objection can be maintained by the Resondent No. 5. [R-8]
 “Though the High Court on one stage held that a candidate for Assistant Professor in Neuro Surgery must have a postgraduate degree in Neuro Surgery and having held that the degree of Neuro Surgery of the appellant was recognized and valid, yet committed a serious error in giving preference to respondent No. 5, which was having a degree of M.S. in General Surgery over the appellant who was holding much higher degree of M. Ch. in Superspecialty in Neuro Surgery itself. The High Court further committed an error in holding that clauses 2 & 3 of the advertisement did not evolve any distinction of specialty, parent specialty and superspecialty. A mere perusal of the said clauses would show that clauses 2 © and 3© does talk of parent specialty and superspecialty. The finding of the High Court in this regard was clearly erroneous. Clause 3 (c) carved out an exception in favour of superspecialty vis-à-vis experience and, therefore, clause 3 clearly speaks about superspecialty. The High Court in our view committed a further error in not appreciating clause 19 in its correct perspective. Clause 19 envisaged that preference would be given to a person who had a degree in superspecialty along with research or working experience. Thus the appellant having a degree in superspecialty and also having preference in the matter of appointment to the post of Assistant Professor in Neuro Surgery over respondent No. 5 who did not have a degree in superspecialty”. [R-8]
“The State Government has also taken a clear stand that there was an acute shortage of qualified Neuro Surgeons in the State and therefore, the Government had provided certain relaxations and priorities in the criteria for appointment to junior teaching posts in various Medical Colleges of Bihar, so that such candidates could be appointed. The appellant had been given preference by virtue of his having M. Ch. Degree in Neuro Surgery with research work and working experience. The State Government has further stated that appellant is qualified Neuro Surgeon and has been rightly appointed as Assistant Professor of Neuro Surgery vide Notification No. 1144 (17) dated 28-12-1990 and the appellant joined the said post on 28-12-1990 itself”. [R-8]
Thus taking in view the entire scheme of the degree and the relevant clauses of the advertisement, we are clearly of the view that appellant was rightly put in the Select Panel at NO. 1 and the Government of Bihar rightly appointed him on the post of Assistant Professor of Neuro Surgery.
In the result, we allows the appeals, setting aside the order of the High Court of Patna dated 10-12-1990 and dismiss the writ petition filed by Dr. Chandra Mohan Jha, Respondent No. 5. In the facts and circumstances of the case, there would be no order as to cost. [R-8]
Most important case of Supreme Court on this issue is that of 1999 [R-6], judgment delivered by a Bench of Chief Justice of India M.M. Punchhi, and his companion Judges K.T. Thomas and D.P. Wadhwa, JJ.
Constitution of India, Arts. 226, 254 – Education – Admission – Medical College – Admission Capacity – Fixation – can be done only by Medical Council – State Government and Universities cannot increase admission capacity.
  • Medical Council Act, 1956 (Act 102 of 1956), Ss. 10-A, 10-B, 33.
  • Karnataka Education Institutional (Prohibition of Capitation Fees) Act (1984), S. 4.
  • Karnataka State Universities Act, 1976 (Act 28 of 1976), S. 53 (10).
  • Dentists Act, 1948 (Act 16 of 1948), S. 10-A.
It is the Medical Council / Dental Council which can prescribe the number of students to be admitted in medical courses / dental courses in a medical college or institution. It is the Central Government, alone which can direct increase in the number of admissions but only on the recommendation of the Medical Council. Universities and the State Government of Karnataka had no authority to allow increase in the number of admissions in the medical colleges in the State. No medical college can admit any student in excess of its admission capacity fixed by the Medical council subject to any increase thereof as approved by the Central Government and that Sections 10-A, 10-B and 10-C will prevail over Section 53(10) of the State Universities Act and Section 41 (b) of the State Government Capitation Fee Act. To say that the number of students as permitted by the State Government and or University before June 1, 1992 could continue would be allowing an illegality to perpetuate for all time to come. [Par 31, 32]
It is not that only future admissions will have to be regulated on the basis of capacity fixed by or determined by the Medical Council. Plea of the State Government that power to regulate admission to medical college is prerogative of the State has to be rejected.
It is the Medical Council, which is primarily responsible for fixing standards of medical education and over seeing that these standards are maintained. It is the Medical Council, which is the principal body to lay down conditions for recognition of medical colleges, which would include the fixing of intake for admission to a medical college. The Medical Council Act is reliable to Entry 66 of List 1 of Schedule 7 to Constitution.
(B) Medical Council Act, 1956 (Act 102 of 1956), S. 33 – Regulations framed under – Falling within the purpose mentioned in Section 33 will have mandatory force.
Recent Developments:
The Hon’ble Chief Justice Ajay Nath Ray and his companion Judge Jagdish Bhalla, of Lucknow Bench of Allahabad High Court, while delivering interim order in a case [R-5] on April 20, 2005 said

This is a Public Interest Litigation (Writ Petition under Article 226 of the Constitution of India) filed by the writ-petitioners, which described themselves as Doctors.

They are final year students of M.B.B.S. Course at B.R.D. Medical College, Gorakhpur. The main substance of the writ petition is that the Post Graduate courses of the said Medical College have been substantially de-recognized by the Medical Council of India but this fact notwithstanding, admissions are going on in these Colleges and the Post Graduate Medical Courses even now. We are informed from the Bar that counseling is on from this day, i.e. today with regard to such Post Graduate Medical Courses.
Some other Colleges are also named in the petition like Maharani Laxmi Bai Medical College, Jhansi and S.N. Medical College Agra. As for as we have been able to gather today, these colleges are not legal personalities and are not Bodies Corporate, these are basically State instrumentalities. The State also appears to have issued directives to at least the B.R.D. medical College, Gorakhpur, not to admit students and not to recognize students to Post Graduate Courses
The writ-petition is directed towards making the recognition available again to these colleges by increasing the teaching staff, making the Laboratories better equipped, and such like.
We are told that a writ petition has also been filed in the Delhi High Court (since the Medical Council is in Delhi) and that in the said writ, orders have been passed calling for reports and for bettering of facilities and that the matter is due to be heard again on the 28th of this month (28-04-2005).
So far as the admissions to unrecognized medical seats are concerned, we have, although prima facie, a very strong view. The Medical Council is the over all supervisor of Medical Education in India. Whether an institution is fit to admit students for the purpose of study ultimately with the aim of receiving medical degrees from that institution, is a matter, which is in the sole decision of Medical Council. If the Medical Council de-recognizes institutions, courses or seats, then and in that event it means that those institutions, those courses or those seats, as the case might be, are not fit for producing qualified doctors of that level or that mentality, specialty.
In such an event, it is the job of every public authority in India to see to it that these deficient institutions do not admit students or grant them degree which would have inbuilt and hidden incapacity and inadequacy and which would forever in future be of definite danger to the citizen of India at large.
Just as an unqualified man practicing medicine is a threat to public health, so also is a half qualified or badly qualified person is a similar danger to the public. If anything the danger in the second case is more. Thus, a degree from an unrecognized institution, course or seat is a misrepresentation. It is a misrepresentation of a permanent nature which is likely to mislead many and unknowing patient.
In these circumstances we admit the writ petition. The writ petitioners are directed to score out doctors from their description in the cause title. They are directed to implead the Medical College concerned by impleading those through their Principal; the present incumbent in office to be served in that regard but the impleading to be made by the office itself.
Until further orders of the Court the respondents, their servants, officers and agents, the respective colleges including B.R.D. Medical College, Gorakhpur, and their Principles, Professors, employees and servants are restrained from taking any steps towards any fresh admission of any medical student to any course or seat which is not at the time of admission recognized by the Medical Council of India.
Petition is to be served on all the added parties. Affidavit would be called for from them after service is completed and the matter will appear in the person 1st respondent, 2 and 3 are represented today before us by Mr. Sanjay Bhasin. The other respondents already on record should also be served, if not already served. The matter should appear in the last four weeks hence. The appearing respondents might keep their affidavits ready after the orders and under directions would be passed on the next date when the court takes of the matter. The impleadment shall be made as above   of the Medical Colleges through the Principal or it added that it should also be served of the Medical University through the Registrar of the University state might require.
It is clarified that if the Medical Council grants recognition the restriction against     impressed by our order would automatically be lifted as the restriction order themselves clarify. Case is still pending and final decision is awaited till date.
Letter written by the Director Medical Education, U.P. [R-3] introduced to Principals of Medical Colleges Kanpur, Agra, Allahabad, Meerut, Jhanshi, Gorakhpur and Registrar King Gorge Medical University on the subject of ‘Recognition of Postgraduate Medical Education’ asking principal’s to take appropriate action as per MCI norms to get Postgraduate degree recognized, and to fulfill deficiencies pointed out by the MCI during previous inspections and inform the MCI of action taken in this regard.
The MCI Letter written by the Secretary MCI [R-4] introduced to the Secretary (Health), Govt. of U.P. on the same subject mentions that
“I am directed to inform you that various postgraduate medical courses are being run in the medical colleges in your State which are yet to be approved / recognized u/s 11 (2) of the IMC Act, 1956. (List enclosed)
You are requested to direct the authorities of the medical colleges to approach the Registrar of the University to which the Medical College is affiliated to forward its formal request through the Central Government as required u/s 11 (2) of the IMC Act, 1956 for arranging for the inspection by the Medical Council of India at the time of practical examination of respective PG Courses.
In addition you are requested to direct the college authorities to send compliance regarding the deficiencies pointed out by the Council in respect of the postgraduate courses which have yet not been recommended for recognition for further necessary action in the matter”. [R-4]
Summary and Conclusions:
Responsibilities should be fixed on concerned authorities for not getting recognized medical degrees / diplomas in time and raising the problem out of control. No initiative was taken by the faculty members due to reasons best known to them. It might be for the reason of insecurity for themselves or no awareness about the procedure of recognition by the MCI. It might be due to bureaucratic or technocratic insensitivity about the issue of public interest.
This problem of non-Recognition of degrees/diplomas results in unnecessary litigations in various courts, denial of job to many degree holders, not receipt of call for interview by UPSC, New Delhi, and even not allowed to appear in interviews like by PGIMER, Chandigarh, and mental harassment of candidates, etc.
Over and above when one go into the background of this problem it is very easy to make out that this problem is the result of insensitive authorities on this issue and not fulfillment of Minimum Standard Requirement Criteria fixed by the MCI and directly related to quality of medical education and denial of right to health care (under Article 21 of Indian Constitution) of general public.
It is a very important issue of public interest related to violation of Article 21, 14, 16 of the Indian Constitution and other statutory provisions. This problem of non-recognized degrees / diplomas awarded by many Indian Universities is in violation of the Indian Medical Degree Act, 1916, the Indian Medical Council Act, 1956, and its Regulations, etc.
Now MCI may suo motu may recognize these degrees / diplomas and apply the 1993 rules afresh while inspecting and allowing permission for admission to these courses without affecting the rights of those already possessed these degrees/ diplomas.  
R-1-Dr. D.R. Yadav vs. State of Haryana & Others, Civil Writ Petition No. 8561 of 2003; Date of Decision 09-02-2005 (P & H).
R-2-Government Order No. 722/II-B-13 [1] –61 Dated 15-05-1964 regarding Degree, Diploma Recognition published in the Gazette Part II, Page No. 27 at Serial No. 6.
R-3- Director Medical Education, U.P. Letter No. ME/ Student Cell/ 2007/ 3225-26, dated 31-05-2007
R-4- Letter of MCI No. MCI-23(1)/ 2006-Med./ 4163, dated 19-05-2007 introduced to Secretary, Health, U.P Government.
R-5-Dr. Om Prakash & Others vs. State of U.P., Writ Petition No. 1563 (M/B) of 2005 in the Hon’ble High Court of Judicature at Allahabad, Lucknow Bench, Lucknow, date of interim order, 20-04-2005.
R-6- Medical Council of India vs. State of Karnatka and Others, AIR 1998 Supreme Court 2423. Civil Appeal Nos. 3275 with 3576-77 of 1998 (arising out of S.L.P. ( C) Nos. 14839 of 1997 with 20035 of 1997 and 547 of 1998), D/-16-07-1998. W.A. No. 8413 of 1996, dated 16-07-1997 (Kant.) GP/GP/S100261/98/VVG/CSL.

R-7-Dr. B.L. Asawa vs. State of Rajasthan and Others, Civil Appeal No. 303 of 1976 (Appeal by special leave from the Judgment and Order dated October 30, 1974 of the Rajasthan High Court in D.B. Civil Appeal No. 247 of 1974), decided on March 5, 1982.

R-8-Dr. Arun Kumar Agarwal v. State of Bihar & Others, A.I.R. 1991 S.C. 1514; J.T. (1991) 2 S.C. 352.
R-9-Dr. Harish Bajaj v. R.D.V. Vidyalaya, Jabalpur, AIR 2003 MP 114.

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