Madhya Pradesh High Court Rules in Favor of Type-1 Diabetic Student Denied Admission Due to Medical Condition

Court Orders Immediate Admission of Pragyansh Tak to B.P.Ed Course, Citing Violation of Fundamental Rights and Discrimination

In a landmark judgment, the Madhya Pradesh High Court has directed the immediate admission of Pragyansh Tak, a Type-1 diabetic student, to the Bachelor of Physical Education (B.P.Ed) course, after he was initially denied entry on medical grounds. The Division Bench at Gwalior, comprising Justices Anand Pathak and Pushpendra Yadav, ruled that the denial constituted a violation of Articles 14 and 21 of the Indian Constitution and the Rights of Persons with Disabilities (RPWD) Act, 2016.

The petitioner, Pragyansh Tak, a state and district-level badminton player, had cleared all requisite examinations and physical tests for the B.P.Ed course. However, his admission was rejected during the medical examination phase due to his Type-1 diabetes condition. Tak had offered to manage his dietary needs and insulin requirements independently, ensuring no burden on the university.

Arguing on behalf of Tak, Advocate Prashant Sharma highlighted that the university's brochure did not disqualify candidates on the basis of Type-1 diabetes. Moreover, medical opinions, including one from AIIMS, Jodhpur, confirmed that Tak could manage his condition with minimal accommodations, such as extra snacks during extended physical activities.

The court observed that the university's refusal to admit Tak was arbitrary and discriminatory, emphasizing the principle of reasonable accommodation as enshrined in the RPWD Act. The judges noted that Type-1 diabetes is not classified as a disability under the Act and that exclusion based on this condition is unjustified.

Citing precedents from the Supreme Court, the judgment underscored the importance of individualized assessments rather than rigid medical criteria. The court drew parallels with notable sports personalities who have successfully managed Type-1 diabetes, thereby reinforcing that the condition should not impede educational pursuits.

The court's decision mandates the university to not only admit Tak but also cooperate in providing necessary accommodations to manage his condition. This judgment is expected to set a precedent for similar cases, reinforcing the rights of individuals with medical conditions to pursue education without discrimination.

Bottom Line:

Type-1 Diabetes cannot be ground to deny admission to a student in an educational course. Denial of reasonable accommodation for Type-1 diabetic students constitutes discrimination under Articles 14, 21 of the Constitution and the Rights of Persons with Disabilities Act, 2016.

Statutory provision(s): Articles 14, 21 of the Constitution of India, Rights of Persons with Disabilities Act, 2016, Sections 2(y) and 14

Pragyansh Tak v. Union of India, (Madhya Pradesh)(DB)(Gwalior) : Law Finder Doc Id # 2812475