Court holds Mahatma Gandhi Medical College liable for admitting students to unrecognized Radiology diploma without infrastructure, mandates refund of bond and stipend plus Rs. 7 lakh for mental agony and career loss
In a landmark judgment dated August 20, 2026, the Jharkhand High Court, presided over by Justice Ananda Sen, has ruled in favor of Dr. Mahesh Kumar, a postgraduate medical student who was admitted to an unrecognized Diploma in Medical Radio Diagnosis (DMRD) course at Mahatma Gandhi Memorial Medical College (MGM), Jamshedpur. The Court found that the college's admission of students into a non-recognized course, coupled with the lack of basic academic infrastructure and coercion to sign a hefty bond, constituted a fraudulent practice causing significant harm to students' careers.
Dr. Kumar, who had completed his MBBS from Moti Lal Nehru Medical College, Allahabad, qualified NEET-PG 2019 and opted for the MGM Medical College’s DMRD course. Upon joining, he was compelled to sign a bond that imposed a penalty of Rs. 30 lakhs for relinquishing the seat and had to submit his original certificates. However, it soon emerged that the Radiology department lacked qualified faculty, essential equipment such as a functional CT machine and an MRI machine, and the course itself was not recognized by the Medical Council of India (MCI).
Despite oral disclosures by the college about the course’s unrecognized status, the Court emphasized that such prior information does not legitimize admission into an unrecognized medical course. The Court held that admission to a course lacking statutory recognition and infrastructure is inherently fraudulent. The bond signed under these misrepresentations was declared invalid. The college’s act of collecting substantial fees and bond amounts from students under these circumstances was branded mala fide.
The Court further observed that the Medical Council of India’s failure to take prompt action against MGM Medical College represents a serious lapse in regulatory oversight. It criticized the college for sending a doctor holding an unrecognized diploma to serve in rural areas, terming it “sacrilegious.”
Due to these deceptive practices, Dr. Kumar lost two valuable years of his career and suffered mental distress. The Court ordered MGM Medical College to immediately refund Rs. 39,94,645 deposited by Dr. Kumar as bond and stipend and awarded an additional Rs. 7,00,000 as compensation for mental agony and career loss. The petitioner was also absolved from any liabilities under the bond. The Court directed the State Finance Department to deduct the amount from the college’s allocation if the institution failed to comply within three weeks.
This judgment sends a stern message to medical colleges and regulatory bodies to strictly enforce recognition and infrastructure standards before admitting students to postgraduate courses. It also highlights the judiciary’s commitment to protect students’ rights against fraudulent educational practices.
Bottom Line:
Medical College offering an unrecognized postgraduate diploma course commits fraud by admitting students and making them sign bonds. Admission to unrecognized courses and lack of basic infrastructure amounts to malpractice and causes significant harm to students' careers.
Statutory provision(s): Medical Council of India Act (erstwhile), NEET-PG Regulations.
Dr. Mahesh Kumar v. State of Jharkhand, (Jharkhand) : Law Finder Doc Id # 2973672
