Case Title: Kabir Paharia v. National Medical Commission & Others
*Special Leave Petition (Civil) No. 29275 of 2024
Citation: 2025 LiveLaw (SC) 532
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Date of Order: May 2025
Summary:
The Supreme Court of India, in a landmark ruling, directed the All-India Institute of Medical Sciences (AIIMS), New Delhi, to allot a seat in the MBBS UG Course 2025–26 to Kabir Paharia, a Scheduled Caste (SC) candidate with benchmark disabilities, who was earlier denied admission due to congenital absence of multiple fingers on both hands and involvement of his left foot.
The Court held that the denial of admission to the Appellant—despite his qualifying NEET-UG 2024 with an SC/PwBD category rank of 176—was “grossly illegal, arbitrary, and violative” of his fundamental rights under Articles 14 and 16 of the Constitution. The judgment emphasized that reasonable accommodation is a constitutional obligation, not an act of charity.
Background:
Kabir Paharia, a meritorious NEET-UG 2024 candidate, was initially denied a disability certificate under the National Medical Commission (NMC) guidelines. He approached the Delhi High Court, which constituted a three-member Medical Board that found him ineligible. A subsequent appeal was dismissed after a similar finding by another board.
He then approached the Supreme Court by way of a Special Leave Petition. The apex court, on April 8, 2025, ordered a fresh assessment—the fourth—by a five-member Medical Board at AIIMS, New Delhi. The Board concluded that the appellant had successfully adapted to his condition and was functionally capable of performing the tasks required in medical education, with the only minor difficulty being in donning sterilized gloves.
Key Observations:
Justice Sandeep Mehta, writing for the Bench, observed:
“We feel that the mindset must change and this trivial aberration, by no stretch of imagination, can be a ground to deny admission to the appellant in the MBBS UG course, when he is otherwise qualified and scored exceeding high rank in the NEET-UG 2024.”
The Court found that another candidate with lower marks had been admitted under the same SC-PwBD category, thereby establishing institutional bias and systemic discrimination. Since the 2024–25 academic session had progressed, the Court directed that the appellant be accommodated in the 2025–26 session without requiring him to reappear for NEET.
Directions to NMC:
The Court further directed the National Medical Commission to revise its guidelines on admission of PwBD candidates within two months, and certainly prior to the 2025–26 counselling session, in light of its rulings in:
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Om Rathod v. Director General of Health Sciences (2024)
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Anmol v. Union of India & Ors (2025)
The Bench reaffirmed the legal position that the presence of a benchmark disability cannot be a blanket ground for disqualification and that admission decisions must be based on individualised, evidence-based assessments rather than rigid or stereotypical standards.
Constitutional Emphasis:
The Court powerfully concluded:
“Reasonable accommodation is not a matter of charity but a fundamental right flowing from Articles 14, 16, and 21 of our Constitution. The promise of equality must be substantive, not merely formal. Assessment of capabilities must be free from stereotypes and rooted in evidence.”
“When administrative authorities create arbitrary barriers that exclude qualified PwBD candidates, they not only violate statutory provisions but also perpetuate historical injustice and stigmatization.”
This judgment is seen as a significant advancement in disability rights jurisprudence in India, reinforcing the constitutional mandate of inclusivity, equal opportunity, and dignity for persons with disabilities in professional education.
