Legal Analysis: Soumya Ranjan Panda & Ors. vs. Subhalaxmi Dash & Ors

Citation: 2026 INSC 488 (Reportable)
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta (Division Bench)
Date of Decision: May 14, 2026
Nature of Judgment: Civil Appeals under Article 136 of the Constitution of India arising out of special leave petitions challenging the orders of the Orissa High Court concerning transfer of medical students from a defunct college.

Synopsis of the Judgment

Two batches of MBBS students admitted in SRMCH (Odisha) faced an uncertain future when the college’s recognition was not renewed due to deficiencies in infrastructure and faculty. The High Court directed relocation of students to other medical colleges. On appeal, the Supreme Court passed interim orders facilitating the transfer of 123 students to three private medical colleges (KIMS, IMS, Hi‑Tech). The students paid fees at Government rates pursuant to interim directions. The transferee colleges sought reimbursement of the difference between their actual fee structure and the Government rates. The defaulting institution (Selvam Trust) had deposited ₹2 crores with the Court and furnished a ₹10 crores bank guarantee with the MCI/NMC. The Court held that the students should not get a windfall; they were liable to pay fees at the rates of the original college (SRMCH), not Government rates. The amounts deposited by the defaulting Trust were directed to be distributed equally among the three transferee colleges. The students were permitted to make representations to the MCI/NMC for settlement of balance dues. The appeal was closed.

1. Basic Information of the Judgment

• Case Title: Soumya Ranjan Panda & Ors. vs. Subhalaxmi Dash & Ors. (with connected matters)

• Civil Appeal Nos.: Arising out of SLP(C) Nos. 35075-35076 of 2015

• Bench: Justice Vikram Nath and Justice Sandeep Mehta (Division Bench)

• Date of Decision: May 14, 2026

• Citation: 2026 INSC 488 (Reportable)

• Appeal From: Judgment and order dated 18.11.2015 and 09.12.2015 of the Orissa High Court

2. Legal Framework

Laws and Provisions Involved

• Constitution of India, 1950: Article 142 (power of Supreme Court to do complete justice) – interim directions were issued under this provision.

• Medical Council of India Act / National Medica

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