The Supreme Court has held that the State of Rajasthan acted without authority in lowering the minimum NEET qualifying percentile for admission to the Bachelor of Dental Surgery (BDS) course for the academic year 2016–17, declaring such admissions illegal, while simultaneously moulding relief to protect students who had already completed their degrees under interim court orders.
Case Details
- Case Title: Siddhant Mahajan and Others v. The State of Rajasthan and Others
- Court: Supreme Court of India
- Bench: Justice Vijay Bishnoi
- Date of Judgment: 2025
- Citation: 2025 INSC 1458
- Jurisdiction: Civil Appellate Jurisdiction
- Arising From: Judgment dated 04 May 2023 of the Rajasthan High Court, Jodhpur
Background of the Dispute
The batch of appeals before the Supreme Court arose from admissions granted to the BDS course in Rajasthan for the academic session 2016–17 after the State Government permitted a reduction in the minimum qualifying percentile prescribed under the National Eligibility-cum-Entrance Test (NEET).
Under the Revised BDS Course Regulations, 2007, candidates in the general category are required to secure at least the 50th percentile in NEET, with lower thresholds for reserved categories.
Facing a large number of vacant seats after the counselling process, the Federation of Private Medical and Dental Colleges of Rajasthan sought relaxation of the qualifying percentile.
Acting on a communication from the Union Ministry of Health forwarding the representation “for necessary action as deemed fit”, the State Government permitted a reduction of 10 percentile on 30 September 2016, followed by an additional 5 percent relaxation on 4 October 2016.
Admissions were thereafter made not only under the State’s relaxation but, in several cases, even beyond it.
Some colleges admitted students solely on the basis of Class 12 marks, including candidates who had secured zero or negative percentile in NEET.
Statutory Framework Governing BDS Admissions
The Court examined the Dentists Act, 1948 and the Revised BDS Course Regulations, 2007, particularly Regulation II(5), as amended in 2012.
The regulation mandates NEET as the sole eligibility-cum-entrance examination and prescribes minimum qualifying percentiles.
Crucially, the proviso to Regulation II(5)(ii) empowers only the Central Government, in consultation with the Dental Council of India (DCI), to lower the minimum percentile, and that too only when sufficient candidates fail to secure the prescribed cut-off in a particular academic year.
The Court also noted Section 10D of the Dentists Act, introduced in 2016, which reinforces the principle of a uniform entrance examination for dental education across the country.
Course of Proceedings Before the High Court
When the Rajasthan University of Health Sciences refused to enrol students admitted under the relaxed criteria, affected students approached the High Court.
A Single Judge partially allowed the writ petitions in April 2018, regularising admissions made up to the extent of a 10+5 percentile relaxation while directing discharge of students admitted beyond that limit.
The Division Bench affirmed this view in May 2023, holding that the State had acted pursuant to delegated authority from the Central Government.
It further imposed costs of ₹50 lakh on each erring college and directed payment of ₹25 lakh compensation to each affected student admitted beyond the permissible relaxation.
Issues Before the Supreme Court
The Supreme Court was called upon to decide whether the State of Rajasthan had the authority to reduce the NEET qualifying percentile, whether any admissions made pursuant to such reduction could be treated as valid, and what relief, if any, could be granted to students who had already completed their courses during the pendency of litigation.
Court’s Observations on NEET and Regulatory Discipline
Reiterating settled law, the Court emphasised that admissions to MBBS and BDS courses must be strictly on the basis of NEET merit, as laid down in Sankalp Charitable Trust v. Union of India and reaffirmed in Christian Medical College Vellore Association v. Union of India. NEET, the Court observed, is a regulatory mechanism to ensure uniform standards, merit-based admissions, and transparency in professional education.
The Bench underlined that regulatory norms framed by statutory bodies such as the DCI cannot be diluted by executive action of State Governments, even in the face of vacant seats.
No Delegation of Power to the State
Rejecting the reasoning of the High Court, the Supreme Court categorically held that the phrase “necessary action as deemed fit” used by the Central Government in its letter dated 29 September 2016 could not be construed as a delegation of statutory power.
“There is no provision under the Dentists Act or the 2007 Regulations which permits delegation of the power to lower the minimum qualifying percentile to a State Government,”
the Court held, adding that the State’s action in reducing the percentile by 10 and then 15 points was “manifestly illegal”.
The Court clarified that at best, the State could have made a recommendation to the Central Government or the DCI. Acting unilaterally to alter eligibility criteria was beyond its competence.
Admissions Held Illegal in Law
The Bench concluded that all admissions made pursuant to the State of Rajasthan’s relaxation policy were legally unsustainable.
The Court further observed that admissions granted by private colleges beyond even the State-sanctioned relaxation amounted to blatant violations of statutory norms and undermined standards of dental education.
The Court agreed with the DCI that the power to lower qualifying marks vests exclusively with the Central Government and cannot be exercised by any other authority.
Equitable Relief for Students Who Completed the Course
At the same time, the Court took note of the peculiar facts. Many students admitted under the impugned relaxations had completed their BDS courses over the years, largely due to interim orders of the High Court permitting them to continue their studies and appear in examinations without claiming equity.
Balancing strict legality with fairness, the Court exercised its powers under Article 142 of the Constitution to protect the degrees of students who had completed the BDS course within the permissible maximum duration prescribed under the Regulations.
The Court, however, made it clear that such relief was confined to the exceptional circumstances of the case and would not operate as a precedent.
Liability of Colleges and Authorities
The Supreme Court endorsed the view that private dental colleges had acted irresponsibly in granting admissions far beyond permissible limits, often to candidates with negligible or negative NEET scores.
Such conduct, the Court observed, was driven by commercial considerations and posed a serious threat to the quality of healthcare education.
While examining the proportionality of penalties imposed by the High Court, the Court emphasised that institutions cannot escape consequences by shifting blame to administrative confusion or delayed decisions by authorities.
Final Directions
The Court set aside the High Court’s finding that the State Government had validly exercised delegated power to lower NEET qualifying percentiles. It held the relaxations granted by the State to be unlawful.
However, degrees already completed by students within the statutory timeframe were protected on equitable grounds.
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Siddhant Mahajan and Others v. The State of Rajasthan and Others
