Eligibility Condition in Admission—Subsequent Compliance—Course Completion Allowed. Educational Eligibility—Initial Ineligibility for Admission to B.A.M.S.—Subsequent Compliance—Doctrine of Actus Curiae Neminem Gravabit Applied—Order of High Court Set Aside


Summary of Judgement

Constitution of India, Article 136—Special Leave Petition—Educational Qualification—Admission Eligibility Condition—Subsequent Compliance
a. The appellant, initially ineligible for admission to the B.A.M.S. Degree Course due to non-fulfillment of the English subject requirement in the 10+2 examination, later fulfilled the requirement by reappearing and passing the subject during the pendency of litigation. [Para 5]
b. The High Court dismissed the writ petition and review petition on the ground that the appellant was not eligible at the time of initial admission, disregarding the fact that he had completed the entire course and part of his internship. [Para 6]
c. The Supreme Court held that the appellant's subsequent compliance with the eligibility condition, along with the peculiar facts of the case, warranted interference to avoid rendering years of academic effort futile. [Para 8]
d. Doctrine of Actus Curiae Neminem Gravabit applied—an act of the court should not prejudice anyone. [Para 8]
e. High Court's orders were set aside, and the appellant was permitted to complete his course and internship, with authorities directed to issue the B.A.M.S. degree. [Para 9]

Subjects: Eligibility Condition—B.A.M.S. Admission—Subsequent Compliance—Interim Protection—Judicial Interference—Educational Qualification

Case Title: Zaid Sheikh Versus The State of Madhya Pradesh and others

Citation: 2025 LawText (SC) (3) 180

Case Number: CIVIL APPEAL NOs. --------- & -------- OF 2025 (@ S.L.P.(C) Nos. 4361-4362 of 2019)

Date of Decision: 2025-03-18