In a powerful reaffirmation of disability rights in the realm of professional education, the Supreme Court of India in Anmol v. Union of India & Ors., 2025 SCC OnLine SC 387, directed the admission of a disabled candidate to an MBBS program under the PwD quota. The verdict marks a significant jurisprudential evolution under the Rights of Persons with Disabilities Act, 2016 (RPwD Act), reinforcing the doctrine of reasonable accommodation and functional assessment over rigid disability benchmarks.
🔍 Background
The appellant, Anmol, a person with multiple disabilities including a 58% locomotor and speech disability, had cleared NEET-UG 2024 and secured a high rank (2462) in the OBC-PwD category. However, the Disability Assessment Board at Chandigarh summarily declared him ineligible for the MBBS program without assessing his functional capabilities. His plea was dismissed by the Punjab and Haryana High Court, citing deference to expert opinion.
The Supreme Court intervened and directed the All India Institute of Medical Sciences (AIIMS) to reassess Anmol. Notably, Dr. Satendra Singh, an eminent disability rights expert, was co-opted into the Medical Board. While five members rejected Anmol’s eligibility citing outdated National Medical Commission (NMC) guidelines, Dr. Singh issued a separate, detailed report supporting Anmol’s admission with clinical accommodations.
⚖️ The Supreme Court’s Analysis
The Court emphasized three fundamental issues:
- Functional Assessment vs Quantified Disability: The Court noted the absence of detailed reasoning from the AIIMS board and reaffirmed that quantified disability alone cannot bar eligibility.
- Ableism in Guidelines: The “both hands intact” requirement in the NMC’s Appendix H-1 was held to be overbroad, discriminatory, and violative of Articles 14 and 21 of the Constitution.
- Reasonable Accommodation is a Right: Building on Omkar Ramchandra Gond and Om Rathod, the Court reiterated that the right to education includes tailored accommodations, assistive technologies, and equitable opportunities.
📘 Legal Framework Cited
- RPwD Act, 2016: Sections 2(h), 2(y), and principles of inclusive education and reasonable accommodation.
- Article 14 & 21: Equality before law and protection of life and liberty.
- Article 41: Directive Principle encouraging the State to provide for education and employment to persons with disabilities.
- UNCRPD: The judgment aligns with international commitments under the United Nations Convention on the Rights of Persons with Disabilities.
🔍 Comparative Precedents
- Omkar Ramchandra Gond v. Union of India (2024) – Asserted purposive interpretation of RPwD Act and need for reform in disability assessment.
- Om Rathod v. DGHS (2024) – Supported functional competence over rigid medical categorization and emphasized judicial duty to protect disability rights.
- Vikash Kumar v. UPSC (2021) – Defined “reasonable accommodation” as a constitutional guarantee.
The Court found the five-member AIIMS report insufficient under these precedents and instead upheld Dr. Satendra Singh’s report as legally sound and in alignment with the law and medical education goals.
🛠️ Recommendations by Dr. Singh
- Assessed the appellant’s ability using simulation tools.
- Suggested reasonable accommodations including assistive technologies, scribes, and modified clinical procedures.
- Emphasized interactive evaluations focused on ability, not deficit.
🚨 Directions to NMC
The Court reiterated its earlier mandate (from Omkar Gond and Om Rathod) to revise the 2019 guidelines. The NMC is now directed to submit an affidavit regarding updated functional assessment-based policies by March 3, 2025.
🏛️ Verdict
The appeal was allowed. The Supreme Court set aside the High Court’s judgment and confirmed Anmol’s admission to Government Medical College, Sirohi, Rajasthan under the OBC-PwD quota.
✅ Key Takeaways for Legal and Medical Stakeholders
- Disability assessment must be individualized and function-based.
- Reasonable accommodation is a legal entitlement, not a concession.
- Institutions must align policies with RPwD Act and Supreme Court directions.