The Supreme Court ruled that denying MBBS admission to a meritorious PwBD (Persons with Benchmark Disabilities) candidate under the SC-PwBD quota violated Articles 14, 16, and 21 of the Constitution. The Court emphasized reasonable accommodation under the Rights of Persons with Disabilities Act, 2016, overturning NMC’s exclusionary guidelines and directing AIIMS to admit the appellant in the 2025-26 session
Facts Of The Case:
Kabir Paharia, a Scheduled Caste (SC) candidate with 42% locomotor disability (congenital absence of multiple fingers in both hands and toes in the left foot), scored 542 marks in NEET-UG 2024, securing All India Rank (AIR) 176 in the PwBD (Persons with Benchmark Disabilities) category. Despite his high merit, he was denied MBBS admission after medical boards at Vardhman Mahavir Medical College-Safdarjung Hospital and AIIMS, New Delhi declared him “ineligible” under NMC (National Medical Commission) guidelines, citing minor challenges in wearing sterilized gloves. The boards acknowledged his ability to perform critical medical tasks—chest compressions, IV cannulation, intubation, and suturing—but disqualified him based on rigid norms.
Paharia challenged this exclusion before the Delhi High Court, arguing that the refusal violated the Rights of Persons with Disabilities Act, 2016 (RPwD Act), which mandates reasonable accommodations for PwBD candidates. Both the Single Judge and Division Bench of the Delhi HC upheld the rejection, relying on the medical boards’ reports. Aggrieved, Paharia approached the Supreme Court, contending that the NMC’s guidelines were discriminatory and contrary to precedents like Om Rathod (2024) and Anmol (2025), where candidates with severe disabilities were granted MBBS admission with accommodations. The Supreme Court intervened, ordering a fresh medical assessment by an AIIMS board, which confirmed Paharia’s functional adaptability, paving the way for his admission.
Procedural History:
The case originated when Kabir Paharia, after being denied MBBS admission despite qualifying under the SC-PwBD quota, filed Writ Petition (C) No. 12165 of 2024 before the Delhi High Court in September 2024. The Single Judge Bench, while directing a fresh medical evaluation by AIIMS, ultimately dismissed the petition on 10th September 2024, accepting the medical board’s opinion that Paharia was ineligible under NMC guidelines. Paharia then appealed through Letters Patent Appeal No. 967 of 2024 before the Division Bench of the Delhi High Court, which, despite ordering a second medical assessment, upheld the rejection on 12th November 2024.
Aggrieved by the High Court’s orders, Paharia approached the Supreme Court via Special Leave Petition (Civil) No. 29275 of 2024, which was converted into a civil appeal. The Supreme Court, in its interim order dated 2nd April 2025, constituted a five-member medical board at AIIMS for a fresh evaluation. Upon receiving the board’s 24th April 2025 report, which confirmed Paharia’s functional capability, the Court heard final arguments and delivered its judgment on 2nd May 2025, setting aside the High Court’s orders and granting relief to Paharia.
Court Observation:
The Supreme Court made several critical observations while adjudicating Kabir Paharia’s case. Firstly, it emphasized that denying admission to a meritorious PwBD candidate like Paharia solely based on rigid medical guidelines violated the constitutional guarantees of equality (Article 14), equal opportunity (Article 16), and right to dignity (Article 21). The Court noted that the Rights of Persons with Disabilities Act, 2016 mandates reasonable accommodation, which was ignored by both the NMC and the medical boards.
The bench particularly criticized the stereotypical assessment of PwBD candidates, highlighting that Paharia’s minor difficulty in wearing gloves could not override his demonstrated competence in performing essential medical procedures like intubation, suturing, and IV cannulation. The Court referenced its earlier judgments in Om Rathod (2024) and Anmol (2025), where similarly disabled candidates were granted admission with accommodations, and stressed that individual capability assessments must replace blanket exclusions.
Additionally, the Court observed that the NMC’s guidelines were outdated and failed to align with the progressive mandate of the RPwD Act. It underscored that reasonable accommodation is not charity but a legal right to ensure substantive equality. The judgment also noted the systemic discrimination in medical education admissions, where qualified PwBD candidates face exclusion due to unfounded presumptions about their abilities rather than evidence-based evaluations.
Final Decision & Judgement:
The Supreme Court delivered a landmark judgment in Kabir Paharia v. National Medical Commission & Others on 2nd May 2025, allowing the appeal and granting relief to the meritorious PwBD candidate. The Court held that denying admission to Paharia under the SC-PwBD quota violated constitutional rights and statutory protections under the Rights of Persons with Disabilities Act, 2016. The bench, comprising Justices Vikram Nath and Sandeep Mehta, directed AIIMS New Delhi to admit Paharia in the MBBS 2025-26 academic session against the SC-PwBD quota based on his NEET-UG 2024 merit (AIR 176 in PwBD category), exempting him from appearing for NEET-UG 2025.
Significantly, the Court mandated the National Medical Commission to revise its admission guidelines for PwBD candidates within two months, incorporating principles of reasonable accommodation and individualized assessment as established in precedents like Om Rathod (2024) and Anmol (2025). The judgment strongly criticized the systemic discrimination against PwBD candidates in medical education and emphasized that constitutional guarantees of equality (Articles 14, 16) and dignity (Article 21) require substantive rather than formal compliance. By setting aside the Delhi High Court’s orders and granting admission without costs, the Supreme Court reinforced the principle that disability cannot be grounds for exclusion when reasonable accommodations can enable equal participation, marking a progressive step towards inclusive medical education in India.
Case Details:
Case Title: Kabir Paharia v. National Medical Commission & Others Citation: 2025 INSC 623 Appeal No.:(Arising from SLP (C) No. 29275/2024) Date: May 2, 2025 Judges: Justices Vikram Nath and Sandeep Mehta Nature: Civil Appeal (Constitutional/Disability Rights)
Download The Judgement Here