Supreme Court Regularises BDS Degrees in Rajasthan Despite NEET Relaxation, Imposes Penalties on Colleges and State

In a significant ruling providing relief to hundreds of students, the Supreme Court of India has regularised the Bachelor of Dental Surgery (BDS) degrees of students who were admitted to private dental colleges in Rajasthan during the 2016–17 academic year after being granted relaxation in the NEET qualifying percentile.

The verdict came as a response to long-pending litigation involving admissions made by private colleges under state-approved relaxations that were later found to be contrary to national regulations. While the court chose to protect the students’ academic careers, it simultaneously took a strict stand against the institutions and authorities responsible for violating admission norms.

Degrees Regularised Using Article 142 of the Constitution

A bench comprising Justices J K Maheshwari and Vijay Bishnoi invoked Article 142 of the Constitution, which empowers the Supreme Court to pass orders necessary to do “complete justice” in exceptional cases.

The court stated that, given the peculiar facts of the case, it was appropriate to regularise the admissions of students who had already completed the BDS course and received their degrees. The judges emphasised that years of effort, time, and financial resources invested by the students could not be undone without causing grave injustice.

As a result, the degrees of all appellant students who had completed their BDS education were declared valid, despite the irregularities in the admission process.

Mandatory Pro-Bono Service Ordered for Beneficiary Students

While granting relief, the Supreme Court attached a significant condition. All students benefiting from the regularisation must submit an undertaking before the Rajasthan High Court stating that they will render pro-bono dental services in Rajasthan during times of natural calamities, man-made disasters, or public health emergencies.

The service obligation can be enforced at any point during their lifetime but is capped at a maximum cumulative period of two years. This condition is intended to balance equity for students with accountability toward public welfare.

The court directed students to file this undertaking with the Registrar (Judicial), Rajasthan High Court, Jodhpur, within eight weeks.

Court Clarifies Relief Is Not a Legal Precedent

The Supreme Court was careful to clarify that this decision should not be treated as a precedent. The bench explicitly stated that the directions were issued only to safeguard the interests of students who had already completed their education under flawed administrative decisions.

By making this distinction, the court reinforced that similar violations of medical education standards in the future would not automatically attract such relief.

Strong Criticism of Private Dental Colleges

The judgment strongly criticised the conduct of private dental colleges involved in the matter. The court noted that 11 private dental colleges, all part of the Federation of Private Medical and Dental Colleges of Rajasthan, had admitted students by granting relaxations far beyond permissible limits.

According to the bench, the colleges committed “blatant illegality” and willful violations of the 2007 Dental Council of India (DCI) Regulations by admitting students beyond the allowed 10+5 percentile relaxation. Such actions, the court said, seriously undermined the standards of medical education in the country.

Rajasthan Government Pulled Up for Unauthorised Relaxations

The Supreme Court also held the Rajasthan government responsible for its role in the controversy. The bench observed that the state had no legal authority to grant relaxation in NEET qualifying percentiles for BDS admissions.

The judgment pointed out that the state failed to communicate in time the decisions of the Central government and the Dental Council of India (DCI) to the colleges, leading to unlawful admissions. This administrative lapse, the court said, contributed directly to the situation faced by the students.

Heavy Financial Penalties Imposed on Colleges and State

To enforce accountability, the Supreme Court imposed substantial financial penalties. Each erring private dental college has been directed to deposit Rs 10 crore, while the Rajasthan government must deposit Rs 10 lakh.

These amounts are to be paid within eight weeks of the judgment and deposited with the Rajasthan State Legal Services Authority (RSLSA).

Utilisation of Funds for Social Welfare in Rajasthan

The court issued detailed instructions on how the deposited funds are to be used. The Rajasthan State Legal Services Authority must invest the money in a short-term fixed deposit in a nationalised bank with an auto-renewal facility.

Importantly, only the interest earned on this deposit may be utilised. The funds are to support the maintenance, upgradation, and improvement of:

• One Stop Centres
• Nari Niketans
• Old Age Homes
• Child Care Institutions run by the Rajasthan government

The utilisation of these funds will be supervised by a five-judge committee of the Rajasthan High Court, including at least one woman judge, to ensure transparency and effective deployment.

NEET-Based Admissions and Legal Standards Reiterated

Reaffirming established law, the Supreme Court referred to its 2016 ruling, which mandates that all MBBS and BDS admissions—whether in government or private colleges—must be strictly based on NEET merit.

The court reiterated the minimum qualifying percentiles for BDS admissions:

• 50th percentile for unreserved category candidates
• 40th percentile for SC/ST/OBC candidates
• 45th percentile for candidates with locomotory disability of the lower limbs

It clarified that any reduction in these cut-offs can only be done under the 2007 Regulations, and solely by the Central government, in consultation with the DCI.

What the Judgment Means for Medical Education Governance

This ruling sends a strong message on two fronts. First, it reassures students that the judiciary will protect them from administrative failures when they are not at fault. Second, it underscores that medical education standards are non-negotiable, and violations by colleges or state authorities will invite strict consequences.

By combining student relief, financial penalties, and public service obligations, the Supreme Court has attempted to strike a balance between compassion and compliance—while reinforcing the primacy of merit-based admissions in India’s medical education system.