Can a Student Keep MBBS Seat After Fake Caste Certificate? Supreme Court Balances Equity
Supreme Court of India, doctors
Court upheld MBBS admission of a student later found ineligible under ST quota, given that she had completed the degree, but ordered her father to pay Rs 5 lakh compensation
The Supreme Court on August 25, 2025, regularised the MBBS admission of a student who had secured her seat under the Scheduled Tribe category but was later found not entitled to the benefit. By the time her caste certificate was declared invalid, she had already completed her medical degree, internship, and secured admission in a postgraduate course under the general category.
The bench of Justices J B Pardiwala and K V Vishwanathan balanced equity with law, permitting the student to continue her academic journey but directing her father, Sanjiv Vithalrao Palekar, to pay Rs five lakh as compensation since “one eligible meritorious candidate from the Scheduled Tribe category lost the opportunity to pursue the MBBS course".
The Bombay High Court had on July 24, 2023 declined any relief to the girl after having noted that she had suppressed material facts about invalidation of caste certificates of her father and uncle in 1989 and 1991 respectively. It also held the father of girl had resorted to fraud while obtaining the validity certificate in 2007.
Examining the student's appeal, the Supreme Court said, "The facts of this case are quite gross but we need to balance the equities in the wake of a few mitigating circumstances which have come on record''.
The student was born on August 07, 1998. On July 01, 2009, while she was still a minor, a caste certificate came to be issued in her favor certifying her to be belonging to the "Mannervarlu" Scheduled Tribe listed at Sl. no. 27 of the Presidential Order, 1976.
As she was desirous of pursuing MBBS Course, she approached the Scrutiny Committee for verification of her caste certificate through her father on July 30, 2015. Unfortunately, the Scrutiny Committee was unable to undertake the necessary enquiry expeditiously as regards the claim of the appellant of being falling within Scheduled Tribe.
The girl came to be admitted to the MBBS Course on July 24, 2016 on the basis of her caste certificate. She successfully completed her MBBS in the year 2021.
Court noted the materials on record would indicate that all throughout she performed well in the MBBS Course."We should also take notice of the fact that her performance in standard 12th examination was also very good,'' the bench said.
After she completed her final year MBBS Course on May 05, 2021, she took up an internship. In the meantime, the Verification Committee passed an order on July 07, 2022 saying that she does not belong to the "Mannervarlu" falling within the Scheduled Tribe.By the time the Scrutiny Committee passed the order, she had cleared her MBBS and had also secured admission in the PG Course but in the general category.
"Today she is in the second year of the PG course. As the Scrutiny Committee declared her to be not falling within the Scheduled Tribe, the appellant questioned the order by filing writ petition before the High Court,'' the court noted.
Dealing with the dismissal of her writ petition, the bench said, "We may say that the High Court committed no error, much less any error of law, in passing the impugned judgment and order. In fact, the High Court has rightly come down very heavily on the father of the appellant.''
The apex court found the High Court also very correctly took notice of the fact that the earlier invalidation of the tribe claim suffered by the father and uncle of the girl respectively in the year 1989 came to be affirmed by the appellate authority in the year 1991 and this fact was suppressed while obtaining a validity certificate for the appellant from a different committee.
The matter presented a precarious situation, the bench noted. "Here is a case where the appellant, a meritorious student otherwise, has completed her MBBS course and is now pursuing her PG Course. If we dismiss this appeal, that will be the end of her entire career, the bench said.
Court stressed it was conscious of the fact that equity should follow the law.
"However, in the peculiar facts and circumstances of this case, we thought it fit to grant one opportunity to the appellant keeping only one thing in mind, i.e., her career and her life. One and all are responsible for this and we hold the father of the appellant more responsible for creating this imbroglio,'' the bench said.
The suppression of material facts, at the end of the father, ultimately put his own daughter in difficulty, it said.
The girl's father filed an undertaking giving up his claim as belonging to Mannevarlu, scheduled tribe, in terms of the apex court's order of November 28, 2023.
The bench noted the girl has secured admission in the PG course in the general category. Her academic career appeared to be quite good.
"Having regard to the fact that the father has filed an undertaking that his daughter will never seek any benefit on the ground that she belongs to Scheduled Tribe and the father has also given an undertaking that no one in the family would seek any benefit of being members of the Scheduled Tribe, we regularise her admission in the MBBS Course,'' the bench said.
Moreover, court confirmed that the degree certificate already issued to her would stand final.
"With all that we have observed, one thought is still haunting our mind, and i.e., that one eligible meritorious candidate from the Scheduled Tribe category lost the opportunity to pursue the MBBS course. For this, the father of the appellant must compensate in terms of money,'' the bench said.
Therefore, court directed the father of the girl to deposit an amount of Rs 5,00,000 with the National Defence Fund within a period of two months.
"Had the Committee undertaken the necessary verification expeditiously and would have declared that the appellant does not fall within the Scheduled Tribe then probably nothing further would have occurred in the matter,'' it felt.
Partly allowing the appeal, court declared that the girl will not claim the status of “Mannervarlu” Scheduled Tribe ever in future. However, it regularised her MBBS admission.
Case Title: Chaitanya Vs The State of Maharashtra & Ors
Judgment Date: August 25, 2025
Bench: Justices J B Pardiwala and K V Vishwanathan
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