Court holds that mere submission of a demand draft is not enough for readmission and that the MDS course must be completed within six years from admission under Dental Council regulations.
The Andhra Pradesh High Court has dismissed a writ petition filed by a dental postgraduate student challenging the University’s refusal to allow him to continue his Master of Dental Surgery (MDS) course, holding that the request was barred by the maximum six-year period prescribed under the governing regulations.
A division bench comprising Chief Justice Lisa Gill and Justice Challa Gunaranjan ruled that Regulation 11(1) of the Dental Council of India’s Master of Dental Surgery Course Regulations, 2017, clearly mandates that the MDS course must be completed within a maximum of six years from the date of admission. Since the petitioner had joined the course on May 23, 2018, the outer limit for completion expired in May 2024.
The petitioner argued that he had already initiated the process for continuation by submitting a demand draft on March 7, 2023, and that the University wrongly treated his later representation as the operative request. He claimed that the delay in completing the course was due to medical reasons and that the demand draft itself should be treated as a valid request for continuation.
The Court, however, rejected this contention. It noted that the petitioner had not enclosed any formal request letter along with the demand draft and that the University and college records showed no valid application for readmission or continuation before June 2024. The bench observed that even if the March 2023 demand draft were treated as a request, the petitioner still could not complete the course within the mandatory six-year period. The Court also took note of his deficient attendance and repeated failure to clear the first-year basic sciences examination in time.
The bench emphasized that the regulations leave no room for relaxation in such circumstances and that the petitioner’s academic timeline made completion within six years impossible. Finding no legal ground to interfere with the University’s decision, the Court dismissed the writ petition.
The judgment reinforces the strict application of course-duration limits in professional medical and dental education and clarifies that a mere demand draft, without a proper application or request, cannot by itself secure readmission or continuation.
Bottom Line :
Education - M.D.S. Course - Under Regulation 11(1) of the Master of Dental Surgery Course Regulations, 2017, the course must be completed within a maximum period of six years from the date of admission - Mere submission of a demand draft without a formal request does not entitle a candidate to readmission/continuation - Where candidate had deficient attendance and could not complete the course within six years, rejection of request for continuation was valid.
Statutory provision(s): Regulation 11(1) of the Dental Council of India, Master of Dental Surgery Course Regulations, 2017, Article 226 of the Constitution of India, 1950
