Medical Assessment Boards Under NMC Guidelines Cannot Re-Quantify Disability Already Certified Under Sections 56 and 57 of the RPwD Act: Allahabad High Court

"The existence of a column in a form cannot confer substantive jurisdiction that the parent statute withholds; a Guideline framed by the NMC... must yield to, and be read consistently with, the plenary statutory scheme of the Act of 2016." Allahabad High Court held that a Medical Assessment Board constituted under the National Medical Commission (NMC) Guidelines lacks the legal authority to re-quantify the percentage of disability of a candidate already certified by a competent authority under the Rights of Persons with Disabilities Act, 2016 (RPwD Act).

A division bench comprising Justice Shekhar B. Saraf and Justice Abdhesh Kumar Chaudhary observed that the board's mandate is strictly limited to an individualized "Functional Competency Assessment" to determine if a candidate can pursue the MBBS course.

Statutory Primacy of Disability Certificates

The petitioners, all candidates for the NEET (UG) 2026 examination, held valid Disability Certificates and Unique Disability ID (UDID) cards issued by Chief Medical Officers under Section 57 of the RPwD Act. Despite these certifications, which placed their disability at or above the 40% benchmark, the NMC-constituted Medical Assessment Boards unilaterally reduced these percentages during functional assessment, subsequently declaring the candidates ineligible for PwBD (Persons with Benchmark Disabilities) reservation.

Board's Jurisdiction Limited to Functional Assessment

The Court clarified that Sections 56 and 57 of the RPwD Act vest the exclusive power to quantify disability in the designated certifying authority. The NMC Guidelines, framed under the National Medical Commission Act, 2019, cannot override this plenary statutory scheme. The bench emphasized that the Medical Assessment Board is merely tasked with evaluating whether, given their disability, a candidate possesses the functional capacity to complete the MBBS curriculum with reasonable accommodation.

Re-quantification Declared Ultra Vires

The Court held that any attempt by the Assessment Board to re-determine the extent of disability is an exercise of excess jurisdiction. Such actions not only violate the RPwD Act but also offend the Article 14 guarantee of equality by subjecting candidates to a secondary, standard-less determination that could effectively nullify their statutory rights.

"No candidate shall be declared ineligible solely on the basis of the percentage of benchmark disability recorded in the UDID Card or disability certificate."

Judicial Review of Assessment Procedures

 The High Court relied on the Supreme Court’s consistent stance in Omkar Ramchandra Gond v. Union of India, Om Rathod v. Director General of Health Services, and Anmol v. Union of India. These precedents establish that disability percentage alone cannot disqualify a candidate. The Court observed that while the Boards found the petitioners "functionally competent" to pursue medical education, they paradoxically denied them reservation benefits based on unauthorized re-calculations of their disability.

The bench quashed the findings of "ineligibility for PwD reservation" while maintaining the findings of "functional competency." It directed the respondent authorities to allow the petitioners to participate in the ongoing NEET (UG) 2026 counseling as PwBD candidates. Furthermore, the Court granted the NMC liberty to issue clarificatory instructions to all Assessment Boards, reiterating that their mandate is restricted to functional assessment and does not permit the re-opening or variation of disability percentages certified under the RPwD Act.

Date of Decision: 23 September 2026