Possible Illegalities
Post NEET Interim Order of SC dated 13th May 2013
Background on the Issue of Admission: Framework of
Admission, Concept of All India quotas, punitive action, contempt of court
Admission to
professional colleges are governed by the judgment of this Court in the case of
TMA Pai Foundation & Ors. vs. State of Karnataka & Ors.[i].
[1] The framework of admissions to colleges was discussed in some detail by
this Court. However, even in the case of
Dr.Pradeep Jain & Ors. vs. Union of
India & Ors.[ii],
[2] the concept of an All India quota
came to be introduced while determining
the validity of a domicile requirement in such
admissions. Earlier, 30 per cent of seats in the under-graduate courses
were reserved for this purpose, which came to be modified to 15 per cent seats
for All India quota in the case of Dr.Dinesh Kumar & Ors. vs. Moti Lal
Nehru College, Allahabad & Ors.[iii].
[3] In the case of Dr.Dinesh Kumar & Ors.
vs. Moti Lal Nehru College, Allahabad & Ors.[iv],
[4] this Court also passed directions in
relation to the
manner of notification/announcement of details, results and counselling for
admission, in that
case, for post graduate admissions, which were to be
published in two successive issues of
newspapers, including one national paper in English and at least two
local papers in the language of the State. Declaration of results would
be made four weeks after the examination and academic courses were to
mandatorily begin on the 2nd of May every year.
Again, in the case of Dr.Dinesh Kumar & Ors. v. Moti Lal Nehru
College, Allahabad & Ors.[v],
[5] as some of the States were not
adhering to the prescribed schedule, this
Court took punitive action
against the State
of Uttar Pradesh
and even contemplated action
under the Contempt of Courts Act, 1971.[vi]
[6, 20] [Para 20]
Merit alone must be the criteria for Admission:
transparent and systematic process of admission
Right from Dr.Pradeep
Jain’s case[ii], this Court has always directed that merit alone must be the
criteria for admission to MBBS courses. To make such admissions more
subject-specific, transparent and systematic,
certain further directions were issued by this Court in Shrawan
Kumar & etc. etc. vs. Director General of Health Services
& Anr. & etc.[vii]
[7, 20] [Para 20]
This Court clarified
that candidates who have been allotted a
seat in the second round of counselling will have to
join the
college within 15
days from the date of their personal
appearance and the
whole allotment and admission process to 15 per cent seats
of All
India quota will
be over before the 30th September
of each year, the remaining
seats having been surrendered back to the college/State.
Various judgments of
this Court have sought
to carry forward, with
greater clarity, the fundamental requirement as stated in TMA Pai
(supra) [1] that the admission process
should be fair, transparent and non-exploitative. Every subsequent
judgment of this Court
has attempted to
elucidate one or
other aspect of
this principle. [20] [Para 20]
Issue of irregularities in maintaining the prescribed
schedule
Having noticed that there
have been irregularities in maintaining the prescribed schedule and that the
last few days of the declared schedule are primarily being utilized in an
exploitative manner, on account of charging higher fees for securing admission
and thereby defeating the principle of admission on merit, a three Judge Bench of this Court in the case of Mridul Dhar
(Minor) & Anr. vs. Union of India
& Ors.[viii]
[8] applied the schedule notified by the Medical Council of India (MCI) in
Appendix ‘E’ of the Graduate Medical Education (Amendment) Regulations, 2004
and directed its strict adherence. [20] [Para
20]
The Court
noticed that the
holding of 10+2
examination and declaration of
results is also of
importance for the
entire admission process and, therefore,
directed strict adherence to the Schedule
in all respects and by all
concerned. The date of 30th September
was stated not to be the date of normal admission but is to give opportunity to
grant admission against stray vacancies.
[20] [Para 21]
The Court clarified
that adherence to the time schedule by everyone was a paramount concern. In
that case, the Court
issued a specific
direction to all
the State functionaries, particularly the
Chief Secretaries and
heads of the
concerned Ministries/Departments
participating in the
States/Union Territories, adopting the time schedule and holding the
State examination, to ensure declaration of results on or before
15th June, 2005. They were also required to ensure the appropriate
utilization of All
India quota, to fullest extent, by timely reporting to the
DGHS by
the Deans of
various colleges or any other State authority, informing the DGHS of
the acceptance or rejection of seats by
the students after the first counselling of All
India/State Quota. [20] [Para 21]
Need for timely LOP:
Further, this Court
even took pains to declare the need for adherence to the schedule for receipt of
applications for establishment
of new medical colleges or seats
and the process of the review and recommendation by the Central Government and
the Medical Council of India. [20] [Para 22]
Note: (1)
The information given by the applicant
in Part I
of the application for
setting up a
medical college that is
information regarding organisation, basic infrastructural facilities,
managerial and financial capabilities of
the applicant shall
be scrutinised by the
Medical Council of India through an inspection and thereafter the Council may
recommend issue of letter of intent by the Central Government.
(2) Renewal of
permission shall not be granted to a medical college if the above schedule for
opening a medical college is not
adhered to and admissions shall not be made
without prior approval
of the Central Government.” [20] [Para 22]
Lastly, in the case
of Priyadarshini Dental College
& Hospital vs. Union of India &
Ors.[ix],
[9] this
Court cautioned all concerned that the schedule
specified in Mridul Dhar (8) should
be maintained and regulations should
be strictly followed. The Court suggested that the
process of inspection of colleges, grant of permission or renewal of permission
should also be done well in advance to allow time for setting right the
deficiencies pointed out. [20] [Para 23]
In the case of State
of Bihar & Ors. vs. Dr. Sanjay Kumar Sinha & Ors.[x],
[10] a Bench of this
Court took exception
to the non-
adherence to the time schedules and reiterated
that the admissions
to medical colleges and post-graduate courses were governed by the
orders of this Court and the
regulations issued by the
Medical Council of
India, which must be strictly followed. This Court issued a warning,
that if there was any violation in future, the same shall be treated as default
and viewed very seriously. Further, in
the case of Medical Council of India vs. Madhu Singh & Ors.[xi],
[11] this Court declared two very important principles. Firstly,
it declared that
mid-stream admissions should not
be permitted and secondly, noticing the
practice of compassion in review of such admissions, this
Court also held that late or mid-stream admission, even just four months
after beginning of the classes,
cannot be permitted. [20] [Para 24]
Regulations of MCI are binding:
A consistent
and clear view
held by this
Court is that
the regulations framed by the MCI are binding and
these standards cannot
be deviated from. Reference can
be made to State of M.P. & Ors. vs. Gopal
D. Tirthani & Ors.[xii];
[12] Bharati Vidyapeeth (Deemed University) & Ors. vs.
State of Maharashtra & Anr.[xiii];
[13] Chowdhury Navin Hemabhai & Ors. vs. State of Gujarat &
Ors.[xiv] [14]
and Harish Verma & Ors. vs. Ajay
Srivastava & Ors. [Para 25][xv]
[15, 20]
What consequences should follow where the concerned
authorities, with impunity, violate the time schedule, regulations and order of
merit to give admission to students
in an arbitrary and nepotistic manner?
What is of greater
significance is that this Court has not so far considered or stated as a
principle, what consequences should follow where the Central Government, or the
State Government or Medical Council of
India or the College
itself, with impunity, violate the time
schedule, regulations and
order of merit
to give admission
to students in an
arbitrary and nepotistic manner. Also, we must consider what preventive steps can be taken to avoid such repetitive and
intentional defaults, as well as undue exploitation of the class of students.
[20] [Para 26]
Admissions based on
favouritism necessarily breach the rule of merit on the one hand, while on the
other, they create frustration in the
minds of the students who have attained higher rank in the competitive entrance
examinations, but have not been admitted. We propose to specifically
address this concern in this judgment. [20] [Para 26]
Mandatory requirement:
From the above
discussion and reference to various judgments of this Court,
it is clear
that adherence to
the principle of
merit, compliance with the
prescribed schedule, refraining
from mid-stream admissions and
adoption of an admission process that
is transparent, non-exploitative and fair are mandatory
requirements of the entire scheme. [20] [Para 26]
Adverse
consequences of non-adherence to the prescribed schedules:
Now, let us examine
the adverse consequences of non-adherence to the prescribed schedules. The
schedules prescribed have the force
of law, in as much as they form part of the judgments
of this
Court, which are
the declared law of the land in terms of Article 141
of the Constitution
of India and form part of the regulations of the
Medical Council of
India, which also have the force of law and are binding on all concerned.
It is difficult to comprehend
that any authority can have the discretion to
alter these schedules to suit a given situation, whether such
authority is the Medical Council of
India, the Government
of India, State
Government, University or the selection bodies constituted at
the college level for allotment
of seats by way of counselling. We have
no hesitation in clearly declaring that none of these authorities
are vested with
the power of relaxing, varying or disturbing the
time schedule, or
the procedures of admission, as provided in the judgments
of this Court
and the Medical Council of India Regulations. [20] [Para 27]
Inter alia, the
disadvantages are:
Disadvantages of non-adherence to schedule:
Inter alia, the disadvantages are:
1)
Delay and
unauthorized extension of schedules defeat the principle of admission on merit,
especially in relation to preferential choice of colleges and courses. Magnanimity in this respect, by condoning
delayed admission, need not be shown by the Courts as it would clearly be at
the cost of more meritorious students.
The principle of merit cannot be so blatantly compromised. This was also affirmed by this Court in the
case of Muskan Dogra & Ors. vs.
State of Punjab & Ors.[xvi]
2)
Mid-stream
admissions are being permitted under the garb
of extended counselling or by
extension of periods for admission
which, again, is impermissible.
3)
The delay in
adherence to the schedule, delay in the commencement of courses etc., encourage lowering of the
standards of education in the Medical/Dental Colleges by
shortening the duration
of the academic courses and promoting the chances
of arbitrary and
less meritorious admissions.
4)
Inequities are
created which are prejudicial to the interests of the students and the colleges
and more importantly, affect the maintenance of prescribed standard of
education. These inequities arise
because the candidates secure admission, with or without active connivance, by the
manipulation and arbitrary handling of the prescribed schedules, at the cost of
more meritorious candidates. When admissions are challenged, these students
would run the risk of losing their seats though they may have completed their
course while litigation was pending in the court of competent jurisdiction.
5)
The highly
competitive standards for admission to such colleges stand frustrated because
of non-adherence to the prescribed time schedules. The admissions are stretched
to the last date and then admissions are arbitrarily given by adopting
impermissible practices.
6)
Timely
non-inclusion of the recognised/approved colleges and seats deprives the
students of their right of fair choice of college/course, on the strength of
their merit.
7)
Preference should
be to fill up all vacant seats, but
under the garb that seats should not go
waste, it would
be impermissible to
give admissions in an arbitrary
manner and without recourse to the
prescribed rule of merit. [20] [Para 27]
Expectations from MCI/DCI, Govt. and Universities:
The Medical and
Dental Councils of India, the Governments and the
Universities are expected to act in tandem with each other and ensure
that the recognition for starting of the medical courses and grant of
admission are strictly within
the time frame
declared by this
Court and the regulations. It has come to the notice of this Court that
despite warnings having been issued by this Court and despite the observations
made by this Court, that default and non-adherence to the time schedules shall
be viewed very seriously, matters have not improved. Persistent defaults by
different authorities and colleges and granting of admission arbitrarily and
with favouritism have often invited criticism from this Court. [20] [Para 28]
In the case of Arvind
Kumar Kankane v. State of U.P. & Ors.[xvii],
the Court observed that the process of counseling cannot go on continuously for
a long period and the resultant chain reaction should be checked. Some seats
may have to be left vacant per
compulsion, but, the
process of admission should
stand the test of rationality.
There should be exceptional and fortuitous circumstances
to justify late admission. [20] [Para 28]
In the case of Chhavi Mehrotra (Miss) v. DGHS[xviii], the
Court was even compelled to issue
notice of contempt
to the Director General
of Health Services as to why proceedings under the
Contempt of Courts Act, 1971 be
not taken for non-compliance with the scheme
framed by the
Court for consideration of applications for transfer of students
between colleges and they be not
punished accordingly. The consistent
effort of this Court to direct corrective measures and adherence to law is not
only being thwarted by motivated action on the part of the concerned
authorities, but there has also been a manifold increase in arbitrary
admissions. Repeated defaults have resulted in generating more and more
litigation with the passage of time.
This Court, thus, now views
this matter with
greater emphasis on directions
that should be made
to curb incidents of disobedience. [20] [Para 28]
Obligations of the Court:
The maxim Boni
judicis est causas
litium dirimere places
an obligation upon the Court
to ensure that
it resolves the
causes of litigation in the
country. [20] [Para 29]
Need of the hour:
Thus, the need of
the hour is that binding dicta be
prescribed and statutory
regulations be enforced, so that all concerned
are mandatorily required to
implement the time schedule in its true
spirit and substance. [20] [Para 30]
It is difficult and
not even advisable to keep some windows open to meet a particular situation of
exception, as it may pose impediments to the smooth implementation of laws and
defeat the very object of the scheme. These schedules have been prescribed upon
serious consideration by all concerned. [20] [Para 30]
They are to be
applied stricto sensu and cannot be
moulded to suit
the convenience of some
economic or other
interest of any
institution, especially, in a manner that is bound to result in
compromise of the above-stated
principles. Keeping in view the contemptuous
conduct of the relevant stakeholders, their cannonade on
the rule of merit compels us to
state, with precision and esemplastically, the action that is necessary
to ameliorate the process
of selection. [20] [Para 30]
Directions of the Supreme Court:
Thus, we issue the following directions in rem for
their strict compliance, without demur and default, by all concerned:
i)
The commencement
of new courses or increases in seats of existing courses of MBBS/BDS are to be approved/recognised by the
Government of India by 15th July of each calendar year for
the relevant academic sessions of that year.
ii)
The Medical
Council of India shall, immediately thereafter, issue appropriate directions
and ensure the implementation and commencement of admission process within one
week thereafter.
iii)
After 15th July of
each year, neither the Union
of India nor
the Medical or Dental Council of India shall issue
any recognition or approval for the current academic
year. If any such approval is granted after 15th July of any year, it
shall only be operative for the next academic year and not in the current
academic year. Once the sanction/approval is granted on or before 15th July of
the relevant year, the name of that college and all seats shall be included in
both the first and the second counselling, in accordance with the Rules.
iv)
Any medical or
dental college, or
seats thereof, to
which the
recognition/approval is issued
subsequent to 15th
July of the respective year shall
not be included
in the counselling
to be conducted by the concerned
authority and that college would have
no right to make admissions in the current academic
year against such seats.
v)
The admission to
the medical or dental colleges shall be granted only through the respective
entrance tests conducted by the competitive authority in the State or the body
of the private colleges. These two are the methods of selection and grant of
admission to these courses. However, where there is a single Board conducting
the state examination and there is a single medical college, then in
terms of clause 5.1 of the
Medical Council of India
Eligibility Certificate
Regulations, 2002 the admission can be given on the basis of 10+2 exam marks,
strictly in order of merit.
vi)
All admissions
through any of the stated selection processes have to be effected only after due publicity and
in consonance with
the directions issued by
this Court. We vehemently deprecate the practice of
giving admissions on 30th September of the academic year.
In fact,
that is the date by which, in exceptional circumstances, a candidate duly
selected as per the prescribed selection process is to join the academic course
of MBBS/BDS. Under the directions of
this Court, second counselling should be the final counselling, as this Court
has already held in the case of Ms.Neelu Arora & Anr. v. UOI & Ors.[xix]
[14] and third counselling is not contemplated or permitted under the entire
process of selection/grant of admission to these professional courses.
vii)
If any seats
remain vacant or are surrendered from All India Quota, they should positively
be allotted and admission granted strictly as per the merit by 15th September
of the relevant year and not by holding an extended counselling. The remaining time will be limited to the
filling up of the vacant seats resulting from exceptional circumstances or
surrender of seats. All candidates should join the academic courses by 30th
September of the academic year.
viii)
No college
may grant admissions
without duly advertising
the vacancies available and by publicizing the same through the internet,
newspaper, on the notice board of the respective feeder
schools and colleges, etc. Every effort has to be made by all concerned
to ensure that the admissions are given on merit and after due publicity and
not in a manner which is ex-facie arbitrary and casts the shadow of
favouritism.
ix)
The admissions to
all government colleges have to be on merit obtained in the entrance examination
conducted by the nominated authority,
while in the case of private
colleges, the colleges
should choose their option by
30th April of the relevant year, as
to whether they wish to grant admission on the basis of
the merit obtained in the test conducted by the nominated State authority or
they wish to follow the merit list/rank
obtained by the candidates in the
competitive examination collectively held by the nominated agency for
the private colleges. The option
exercised by 30th April shall not be subject to change. This choice should also
be given by the colleges which are anticipating grant of
recognition, in compliance
with the date specified in these directions. [20] [Para
30]
Directions of SC for Authorities and other stakeholders
for Admission
All these directions
shall be complied
with by all
concerned, including Union of India,
Medical Council of
India, Dental Council
of India, State Governments, Universities and medical and dental colleges
and the management of the
respective universities or
dental and medical colleges. [20] [Para 31]
Warning for consequences and penal action:
Any default in
compliance with these conditions or attempt to overreach these directions
shall, without fail, invite the following consequences and penal actions: [20] [Para
31]
a.
Everybody,
officer or authority who disobeys or
avoids or fails
to strictly comply with these directions stricto sensu shall be liable
for action under the provisions of the Contempt of Courts Act. Liberty is granted to any interested
party to take out the contempt proceedings before the High Court having
jurisdiction over such Institution/State, etc.
b.
The person,
member or authority found responsible for any violation shall be departmentally
proceeded against and punished in accordance with the Rules. We make it
clear that violation
of these directions
or overreaching them by any
process shall tantamount
to indiscipline, insubordination,
misconduct and being unworthy
of becoming a
public servant.
c.
Such defaulting
authority, member or body shall also be liable for action by and personal
liability to third parties who might have suffered losses as a result of such default.
d.
There shall be
due channelization of selection
and admission process
with full cooperation and coordination between the Government of India,
State Government, Universities, Medical
Council of India
or Dental Council of India and
the colleges concerned. They shall act in tandem and strictly as per the
prescribed schedule. In other
words, there should be complete
harmonisation with a view to form a
uniform pattern for concerted
action, according to
the framed scheme,
schedule for admission and
regulations framed in this behalf.
e.
The college which
grants admission for the current academic year, where its recognition/approval
is granted subsequent
to 15th July of the current
academic year, shall be
liable for withdrawal
of recognition/approval on this ground,
in addition to
being liable to indemnify such students who are denied
admission or who are
wrongfully given admission in the
college.
f.
Upon the expiry
of one week after holding of the second counselling, the unfilled seats from all quotas shall be
deemed to have been surrendered in favour of the
respective States and
shall be filled
thereafter strictly on the basis of merit obtained in the competitive
entrance test.
g.
It shall be
mandatory on the part of each
college and University
to inform the State and the
Central Government/competent
authority of the seats which are lying vacant after each counselling
and they shall furnish the complete details, list of seats filled and vacant
in the
respective states, immediately after each counselling.
h.
No college shall
fill up its seats in any other manner. [20] [Para 31]
Triple Test i.e. transparent, fair and
non-exploitatory selection/admission processes:
Having dealt with,
in general, the directions that
this Court would issue
to prevent the
evils of arbitrariness
and discrimination from creeping into these selection/admission
processes, which are required to be
transparent, fair and non-exploitatory, we shall now proceed to
deal with the facts of the
present case. [Para 32]
SC concluded that The
present case is a glaring example of
calculated tampering with the schedule specified under the regulations
and the judgments
of this Court, with a clear
intent to grant
admission to less meritorious candidates over and above the candidates of
higher merit. To put it simply, it
is a case of favouritism and arbitrariness. This also chronicles how, either
way, the careers of the students are jeopardised. [20] [Para 33][xx]
References:
1.
TMA Pai Foundation & Ors. vs. State of Karnataka & Ors. [(2002) 8 SCC 481]
2.
Dr.Pradeep Jain & Ors. vs. Union of India
& Ors. [(1984) 3
SCC 654]
3.
Dr.Dinesh Kumar & Ors. vs. Moti Lal Nehru
College, Allahabad & Ors. [(1985) 3 SCC
22]
4.
Dr.Dinesh Kumar & Ors. vs.
Moti Lal Nehru College, Allahabad
& Ors. [(1987) 4 SCC 459]
5.
Dr.Dinesh Kumar & Ors. vs. Moti Lal Nehru
College, Allahabad & Ors. [(1990) 4
SCC 627]
6.
The Contempt of Courts Act, 1971.
7.
Shrawan Kumar & etc. etc. vs. Director General of Health Services
& Anr. & etc. [(1993) 3 SCC 332]
8.
Mridul Dhar (Minor) & Anr. vs. Union of
India & Ors. [(2005) 2 SCC 65]
9.
Priyadarshini Dental College & Hospital vs. Union of India &
Ors. [(2011) 4 SCC
623]
10.
State of Bihar & Ors. vs. Dr. Sanjay Kumar
Sinha & Ors. [(1990) 4 SCC 624]
11.
Medical Council of India vs. Madhu Singh &
Ors. [(2002) 7 SCC
258]
12.
State of M.P. & Ors. vs.
Gopal D. Tirthani & Ors. [(2003)
7 SCC 83 – paras 24 and 26]
13.
Bharati Vidyapeeth (Deemed University) &
Ors. v. State of Maharashtra & Anr.
[(2004) 11 SCC 755 – para 20]
14.
Muskan Dogra
& Ors. vs. State of Punjab &
Ors. [(2005) 9 SCC 186].
15.
Chowdhury Navin Hemabhai & Ors. vs. State of
Gujarat & Ors. [(2011) 3 SCC 617 – paras 7, 11, 12, 14
and 18]
16.
Harish Verma & Ors. vs.
Ajay Srivastava & Ors. [(2003) 8 SCC 69 – paras 14 to 21]. [Para 25]
17.
Arvind Kumar Kankane v. State of U.P. & Ors.
(2001) 8 SCC 355]
18.
Chhavi Mehrotra (Miss) v. DGHS [(1994) 2 SCC 370]
19.
Ms.Neelu Arora & Anr. v. UOI & Ors.
[(2003) 3 SCC 366]
20.
Swatanter Kumar,
J. Priya Gupta vs. State of Chhatishgarh & Ors., Civil Appeal No. 4318 of
2012, (Arising out of SLP (C) No.27089 of 2011), with Civil Appeal No. 4319 of
2012 (Arising out of SLP (C) No. 29306 of 2011), Date of Judgment: 08.05.2012
[i] TMA Pai Foundation
& Ors. vs. State of Karnataka &
Ors. [(2002) 8 SCC 481]
[ii] Dr.Pradeep Jain &
Ors. vs. Union of India &
Ors. [(1984) 3
SCC 654]
[iii] Dr.Dinesh Kumar &
Ors. vs. Moti Lal Nehru College, Allahabad & Ors. [(1985) 3 SCC 22]
[iv] Dr.Dinesh Kumar & Ors. vs.
Moti Lal Nehru College, Allahabad
& Ors. [(1987) 4 SCC 459]
[v] Dr.Dinesh Kumar &
Ors. v. Moti Lal Nehru College, Allahabad & Ors. [(1990) 4 SCC
627]
[vi] The Contempt of Courts Act, 1971
[vii] Shrawan Kumar &
etc. etc. v. Director General of
Health Services & Anr. & etc.
[(1993) 3 SCC 332]
[viii]
Mridul Dhar
(Minor) & Anr. vs. Union of India
& Ors. [(2005) 2 SCC 65]
[ix] Priyadarshini Dental
College & Hospital
v. Union of India & Ors. [(2011)
4 SCC 623]
[x] State of Bihar &
Ors. v. Dr. Sanjay Kumar Sinha &
Ors. [(1990) 4 SCC 624]
[xi] Medical Council of
India vs. Madhu Singh & Ors. [(2002)
7 SCC
258]
[xii] State of M.P. &
Ors. v.
Gopal D. Tirthani & Ors. [(2003)
7 SCC 83 – paras 24 and 26]
[xiii]
Bharati Vidyapeeth (Deemed University) & Ors. v.
State of Maharashtra & Anr. [(2004)
11 SCC 755 – para 20]
[xiv] Chowdhury Navin
Hemabhai & Ors. vs. State of Gujarat
& Ors. [(2011) 3 SCC 617 –
paras 7, 11, 12, 14 and 18]
[xv]
Harish Verma
& Ors. vs. Ajay Srivastava & Ors. [(2003) 8 SCC
69 – paras 14 to 21]. [Para 25]
[xvi]
Muskan Dogra
& Ors. vs. State of Punjab &
Ors. [(2005) 9 SCC 186].
[xvii]
Arvind Kumar
Kankane v. State of U.P. & Ors. (2001) 8 SCC 355]
[xviii]
Chhavi Mehrotra
(Miss) v. DGHS [(1994) 2 SCC 370]
[xix] Ms.Neelu Arora &
Anr. v. UOI & Ors. [(2003) 3 SCC 366]
[xx]
Swatanter Kumar, J. Priya Gupta vs. State of Chhatishgarh & Ors., Civil
Appeal No. 4318 of 2012, (Arising out of SLP (C) No.27089 of 2011), with Civil
Appeal No. 4319 of 2012 (Arising out of SLP (C) No. 29306 of 2011), Date of
Judgment: 08.05.2012
Dr.Mukesh Yadav
B.Sc., M.B.B.S., M.D., M.B.A. (HCA), LL.B., PGDHR
Editor, Journal of Indian Academy of Forensic Medicine
Professor and Head of Department,
Department of Forensic Medicine & Toxicology
School of Medical Sciences & Research, Sharda University
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Gautam Budha Nagar, NCR, Delhi, pin: 201306
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