In a rare and extraordinary situation, the Supreme Court of India has directed the National Medical Commission (NMC) to explore whether a General Medicine PG seat occupied by a candidate can be converted into a Radio Diagnosis seat.
The direction comes after a dispute between two candidates over the lone postgraduate seat in Radio Diagnosis reserved for Jawaharlal Nehru Institute of Medical Sciences (JNIMS), Imphal sponsored candidates.
A bench of Justices PS Narasimha and Atul S Chandurkar passed the interim order, clarifying that while the Court did not wish to disturb the position of the respondent who now holds the Radio Diagnosis seat, it considered it appropriate to safeguard the interests of the petitioner, who had already spent six months studying the course.
The Court posted the matter for further hearing on August 29, 2025, when NMC’s response will be considered.The Supreme Court’s Order
Quoting from its direction, the Court said:
“In view of a rather extraordinary situation, the National Medical Commission is directed to consider if the seat occupied by the petitioner in General Medicine can be converted as the seat for Radio Diagnosis. This direction, only to consider, is in view of the fact that the petitioner has spent six months pursuing Radio Diagnosis and also for the reason that he is meritorious.”
The bench made it clear that this arrangement would not disturb the entitlement of the respondent No. 4 candidate, who rightfully became eligible for the Radio Diagnosis seat after the cut-off percentile was lowered in the later round of counselling.
Background of the Case
• The Petitioner: Dr. Mutum Anilkumar Singh, Senior Casualty Medical Officer at JNIMS, Imphal.
• The Respondent No. 4: Senior Resident in the Department of Radio Diagnosis, JNIMS.
Both appeared in NEET-PG 2024. Under the 1st Amended Rules, 2022 and the Reservation Scheme, 2022, one Radio Diagnosis PG seat was reserved for JNIMS-sponsored candidates.
In the 3rd round of counselling, the petitioner was admitted to the Radio Diagnosis course, having scored a higher percentile. However, as per the rules, the seat was subject to surrender if another eligible Senior Resident from JNIMS qualified after the cut-off percentile was relaxed in subsequent rounds.
This happened when respondent No. 4 became eligible in the Stray Round Counselling. She immediately submitted a representation asserting her entitlement to the reserved seat, pointing out that the petitioner had to vacate it under the scheme.
The Manipur High Court’s Single Judge avoided deciding on the merits but directed that the petitioner’s admission in Radio Diagnosis be adjusted against a vacant seat in General Medicine.
On appeal, the Division Bench upheld the Single Judge’s order, ruling that:
• The respondent No. 4 had not delayed in asserting her claim.
• The authorities were at fault for not considering her eligibility in time.
• The lone reserved seat in Radio Diagnosis was rightfully hers under the rules.
The High Court also noted that the arrangement of shifting the petitioner to General Medicine protected the interests of both candidates.
Dissatisfied, the petitioner approached the Supreme Court. His counsel, Senior Advocate Shadan Farasat (with AoR Neha Rathi), argued that since the petitioner had already pursued six months of training in Radio Diagnosis and had superior merit, his career should not be jeopardized.
On the other side, Advocate General Lenin Singh Hijam along with Senior Advocate Anupam Lal Das and others defended the High Court’s order, emphasizing that respondent No. 4’s entitlement under the reservation scheme could not be overlooked.
Balancing both interests, the Supreme Court adopted a middle path — by asking the NMC to explore whether a conversion of the General Medicine seat into Radio Diagnosis was legally permissible, thereby avoiding disruption to either candidate.
This case highlights the complexities in NEET-PG counselling, especially under institutional reservation schemes, where changes in cut-off percentiles can alter eligibility even after admissions.
If the Supreme Court ultimately allows such a seat conversion, it could set a precedent for future cases where equities between two meritorious candidates must be balanced without prejudicing one over the other.
Case Title: Mutum Anilkumar Singh v. The State of Manipur & Ors.
Case No.: SLP(C) No. 21750/2025
