In a significant judgment, the Supreme Court of India has reduced the punishment imposed on senior pediatrician Dr. Nigam Prakash Narain in a case relating to alleged non-disclosure during a medical college inspection conducted by the erstwhile Medical Council of India, now replaced by the National Medical Commission.

A Bench of Justice Dipankar Datta and Justice Satish Chandra Sharma held that although Dr. Narain had made a “mis-declaration” by not disclosing his earlier appearance as faculty in another medical college during the same academic year, the punishment of removing his name from the Indian Medical Register for three months was too harsh after nearly a decade of litigation.

The Court invoked its powers under Article 142 of the Constitution and requested the NMC to substitute the penalty with a “censure/warning.”

Dr. Nigam Prakash Narain, a renowned pediatrician and former Professor and Head of the Department of Pediatrics at Patna Medical College, had briefly joined Shridev Suman Subharti Medical College and Hospital after retirement in 2015.

Later, he resigned from the Dehradun medical college and rejoined Patna Medical College on a contractual basis. Before an MCI surprise inspection at Patna Medical College in May 2015, a declaration form signed by Dr. Narain was submitted. The declaration allegedly failed to disclose that he had earlier appeared as faculty during an inspection at the Dehradun medical college in the same academic year.

The Ethics Committee of the MCI eventually held that the omission amounted to serious misconduct and ordered removal of his name from the Indian Medical Register for three months.

The Supreme Court observed that the original show-cause notice accused Dr. Narain of appearing in inspections of two colleges simultaneously using fake declaration forms. However, after Dr. Narain successfully explained that he was abroad attending a medical conference in Amsterdam on the date of the Patna inspection, the authorities shifted the basis of punishment to “non-disclosure” in the declaration form.

The Court held that this new allegation was never part of the original charge and no fresh show-cause notice or hearing was given to Dr. Narain before imposing punishment.

Relying on the decision in Ravi Oraon v. State of Jharkhand, the Bench held that punishment on a completely different charge without giving a fresh opportunity of hearing violates principles of natural justice.

Despite finding procedural irregularity, the Court also noted that Dr. Narain could not satisfactorily explain why the declaration form stated that he had not presented himself to any other institution for MCI assessment during the same academic year.

The Bench observed that such a “brazen mis-declaration” could amount to misconduct and could not simply be ignored.

Relief Granted Under Article 142

Taking into account that:

• the incident dated back to 2015,

• nearly ten years had passed in litigation,

• Dr. Narain is now 76 years old, and

• the penalty had remained stayed during the pendency of proceedings,

the Court concluded that maintaining the three-month removal from the medical register would not serve the interests of justice.

Accordingly, the Supreme Court directed the NMC to replace the punishment with a warning/censure instead of suspension from practice.

The appeal was allowed in these terms.

The judgment reiterates that professional regulatory bodies must strictly follow principles of natural justice before imposing penalties. At the same time, the Court emphasized that incorrect or incomplete disclosures made before regulatory authorities can still amount to professional misconduct.

Case Title: Dr. Nigam Prakash Narain v. National Medical Commission & Ors.
Citation: 2026 INSC 453