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Supreme Court Advises Caution on Interim Orders Directing Colleges to Hold Seats Vacant

In a significant ruling, the Supreme Court of India has cautioned courts against issuing interim orders that direct educational institutions to keep seats vacant, potentially causing financial losses to these institutions. The observation was made by a bench comprising Justices BR Gavai and KV Viswanathan, while considering an appeal by two medical colleges affected by a High Court order mandating them to keep an MBBS seat vacant. This seat, left unfilled as a result of the directive, led to revenue losses for the institutions.


The case stemmed from a directive by the Director of Medical Education, in compliance with an interim order of the Madhya Pradesh High Court, which required that a seat be held vacant during the academic year 2023-24. The High Court order had arisen from writ petitions filed by students. However, by the time these petitions were resolved, the academic counseling process and the admission cut-off date had elapsed, leaving the seat unutilized.


The Supreme Court emphasized that the High Court’s interim order did not adequately consider essential factors, such as the prima facie case, balance of convenience, and potential irreparable harm. Observing that the order adversely impacted the medical colleges financially, the bench directed that these institutions be allowed to seek compensation. The court suggested that the colleges make a representation to the State’s Fee Fixation Committee, which could adjust future fees to offset the revenue deficit caused by the vacant seat.


"This approach will serve justice, as it allows the colleges to recoup their financial losses in a structured manner," the bench noted. The adjustment, spread over future batches, would mitigate the monetary impact on incoming students.


The Court’s decision effectively balanced the financial burden, ensuring that losses caused by judicial directives are not unduly borne by educational institutions. The judgment, which recognized the broader implications of such interim orders, is likely to influence future judicial considerations regarding admissions and seat allocations.


*Case Title:* Ramkrishna Medical College Hospital & Research Centre v. State of Madhya Pradesh & Ors., SLP (C) No. 11785 of 2024


*Citation:* 2024 LiveLaw (SC) 877





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