Legal Review and Analysis of Siddhant Mahajan and Ors vs The State of Rajasthan and Ors 2025 INSC 1458

Case Synopsis 

Siddhant Mahajan and Ors. v. The State of Rajasthan and Ors. (2025 INSC 1458)

Synopsis : The Supreme Court held that the power to relax NEET eligibility for BDS courses rests solely with the Central Government in consultation with the DCI. A state government has no such authority. Admissions based on unauthorized relaxations are illegal. However, using its extraordinary powers, the Court conditionally protected students who had completed their degrees under court orders, while imposing heavy penalties on the erring colleges and the state.

1. Heading of the Judgment
Siddhant Mahajan and Ors. v. The State of Rajasthan and Ors.
Citation: 2025 INSC 1458
Decided on: December 18, 2025
Bench: Hon’ble Mr. Justice J.K. Maheshwari and Hon’ble Mr. Justice Vijay Bishnoi, Supreme Court of India.

2. Related Laws and Sections
The judgment interprets and applies the following legal framework:

• The Dentists Act, 1948 – The statute governing dental education and practice in India.

• Section 10D of the Dentists Act (inserted vide Ordinance dated 24.05.2016) – Providing for a uniform entrance examination for dental courses.

• The Revised BDS Course Regulations, 2007 (as amended by the 5th Amendment Regulations, 2012) – Specifically Sub-regulation 5(ii) of Regulation II. This provision stipulates the minimum NEET percentile for BDS admissions (50th for General, 40th for SC/ST/OBC, 45th for PwD) and contains a proviso stating that the Central Government, in consultation with the Dental Council of India (DCI), may lower these marks if a sufficient number of candidates fail to secure the minimum marks in a given academic year.

• Judicial Precedents on NEET: The judgment reaffirms the principles established in Sankalp Charitable Trust v. Union of India (2016) and Christian Medical College Vellore Association v. Union of India (2020), which mandate that admissions to MBBS/BDS courses must be based solely on NEET merit.

3. Basic Judgment Details

Facts of the Case
For the 2016-17 academic year, a large number of BDS seats in Rajasthan’s private dental colleges remained vacant after the initial NEET-based counseling. The Federation of Private Medical and Dental Colleges of Rajasthan represented to the authorities to lower the qualifying percentile.

• The Central Government, via a letter dated 29.09.2016, forwarded this representation to the State of Rajasthan asking it to take "necessary action as deemed fit."

• Interpreting this as a delegation of power, the State of Rajasthan issued orders lowering the NEET qualifying percentile by 10 percentile (30.09.2016) and later by an additional 5 percentile (04.10.2016).

• Acting on the state's orders, private colleges filled seats. However, many colleges went further and admitted students with relaxations beyond the 15-percentile cut-off, some even admitting candidates with zero or negative NEET scores, based only on their 10+2 marks.

• The Dental Council of India (DCI) and the Central Government subsequently clarified that the State had no such power and directed the cancellation of these admissions. The affected students approached the courts.

• The Single Judge and the Division Bench of the Rajasthan High Court upheld the admissions made within the 15-percentile relaxation but ordered the discharge of students admitted beyond that limit. The colleges were also penalized with heavy fines. Appeals were filed in the Supreme Court by the aggrieved students, colleges, and the DCI.

Issues Before the Supreme Court

1. Whether the State of Rajasthan had the legal authority to lower the minimum NEET qualifying percentile for BDS admissions for the academic year 2016-17?

2. Whether the admissions granted pursuant to the state's relaxation orders, and further by colleges beyond those relaxations, were valid?

3. What relief, if any, could be granted to the students who had pursued and completed their BDS courses under the interim protection of court orders?

Ratio Decidendi (Court's Reasoning)
The Supreme Court reversed the High Court's findings. Its reasoning is structured as follows:

• Statutory Power is Non-Delegable: The Court held that the proviso to Sub-regulation 5(ii) of Regulation II of the 2007 BDS Regulations is unequivocal. The power to lower the minimum percentile is vested exclusively with the Central Government, and that too only in consultation with the DCI. This is a statutory power that cannot be delegated.

• Erroneous Interpretation by High Courts: The Supreme Court rejected the High Courts' interpretation that the Central Government's letter asking the State to take "necessary action as deemed fit" constituted a delegation of power. Such a phrase cannot override the specific statutory mandate.

• Consequences of Illegal Action: Consequently, the State of Rajasthan's orders lowering the percentile were manifestly illegal and without jurisdiction. All admissions made pursuant to these orders, whether within the 15-percentile limit or beyond, were void ab initio (invalid from the outset).

• Colleges Acted with Impunity: The Court strongly condemned the private dental colleges for not only acting on the state's illegal orders but also exceeding them by admitting students with abysmally low NEET scores, thereby making a "mockery" of the regulations and compromising educational standards.

• Balancing Equity and Justice under Article 142: While unequivocally condemning the illegalities, the Court recognized that the students were the ultimate victims. They had pursued their studies over many years under the protection of interim court orders, with many completing their degrees and starting careers/pursuing higher education. To prevent grave injustice, the Court invoked its extraordinary powers under Article 142 of the Constitution.

4. Analysis: Core Principle of the Judgment

The Central Legal Problem
The judgment addresses the conflict between the rigid statutory framework designed to uphold merit in professional medical education (NEET) and the actions of state authorities and private institutions that bypassed this framework under the guise of filling vacant seats.

The Supreme Court's Resolution – The Core Principle
The statutory mandate prescribing NEET as the sole basis for admission and fixing the authority to alter its qualifying criteria is sacrosanct. Neither states nor private institutions can usurp this authority. Any admission made in violation of this mandatory legal framework is inherently illegal, regardless of the reasons (like vacant seats) or subsequent approvals sought. Upholding merit is non-negotiable for maintaining standards in professional healthcare education.

The Court underscored that the existence of vacant seats does not create an emergency justifying a violation of law. The correct course for the State was to recommend action to the Central Government/DCI, not to assume power itself. The judgment reaffirms that in matters of professional education, the rule of law and adherence to regulations must prevail over administrative convenience or the financial interests of private colleges.

5. Final Outcome and Directions

• The Supreme Court allowed the appeals in part, setting aside the High Court's order to the extent it regularized admissions within the 15-percentile relaxation.

• For Students who Completed the Course: As a one-time measure under Article 142, the Court regularized the admissions of those appellant-students who had already passed and obtained their BDS degrees. However, they must file an affidavit undertaking to provide pro bono dental service to the State of Rajasthan for a cumulative period of two years during their lifetime, in times of public health emergencies or disasters.

• For Students who Did Not Complete the Course: Students admitted in 2016-17 who had not cleared the BDS course within the maximum permissible period of 9 years (as per regulations) were granted no relief and stood discharged.

• Penalties Imposed:
  Each of the erring private dental colleges was directed to deposit a cost of Rs. 10 Crores with the Rajasthan State Legal Services Authority (RSLSA).
  The State of Rajasthan was directed to deposit Rs. 10 Lakhs with the RSLSA for its illegal assumption of power.

• Utilization of Penal Funds: The interest accrued on these deposits is to be used for upgrading social welfare institutions (One Stop Centres, Nari Niketans, etc.) under the guidance of a committee of five judges of the Rajasthan High Court.

6. MCQs Based on the Judgment

Question 1: According to the Supreme Court's judgment in Siddhant Mahajan v. State of Rajasthan, who possesses the exclusive statutory authority to lower the minimum NEET qualifying percentile for BDS admissions?

A. The State Government, in consultation with the University.
B. The Dental Council of India, on its own.
C. The Central Government, in consultation with the Dental Council of India.
D. The Private Dental Colleges' Federation, with state approval.

Question 2: What was the primary reason the Supreme Court, invoking Article 142 of the Constitution, granted conditional relief to students who had secured admission with lowered NEET percentiles?

A. The admissions were legally valid from the beginning.
B. The State Government had acted in good faith.
C. The students, as victims of the system, had completed their degrees over many years under court orders, and denying relief would cause severe injustice.
D. The Dental Council of India had granted ex-post-facto approval.