ANMOL versus UNION OF INDIA & ORS.

Citation: [2025] 2 S.C.R. 1142 · Decided: 21-02-2025 · Supreme Court of India · Bench: BHUSHAN RAMKRISHNA GAVAI · Disposal: Appeal(s) allowed
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Judgment (excerpt)

[2025] 2 S.C.R. 1142 : 2025 INSC 256
Anmol 
v. 
Union of India & Ors.
(Civil Appeal No. 14333 of 2024)
21 February 2025
[B.R. Gavai and K.V. Viswanathan,* JJ.]
Issue for Consideration
Appellant appeared in the NEET-UG 2024 Examination and secured 
a rank of 2462 in the Persons with Disability (PwD) category. The 
designated Disability Certification Centre found him ineligible to 
pursue medical course on the basis of his quantified disability. 
When appellant challenged the decision before the High Court 
in a writ petition, it was dismissed on the ground that the Court 
cannot substitute the opinion of the experts in the field of disability. 
Appellant approached the Supreme Court by filing SLP and this 
Court while issuing notice directed Director, All India Institute of 
Medical Sciences (AIIMS) to constitute a six member Committee 
with Dr. Satendra Singh (‘expert’) as a member. A report with two 
parts was submitted by the Committee-one part by the five members 
held that the Appellant is not fit under the present NMC Guidelines 
to pursue MBBS and the second part by Dr. Singh held that the 
Appellant is fit to complete MBBS with clinical accommodations 
and assistive technologies.
The issue before the Supreme Court pertains to reasonable 
accommodation that the National Medical Commission has to 
provide in the Guidelines framed by it for medical admission to PwD.
Headnotes†
Rights of Persons with Disabilities Act, 2016 (‘RPwD Act’) – 
In light of the decision in Omkar Ramchandra Gond v. Union 
of India & Ors., 2024 SCC OnLine SC 2860 – Discussed and 
relied on:
Held: In Omkar Ramchandra Gond case it was held that Article 41 
of the Directive Principles of State Policy casts duty on the State 
to make effective provision for securing the right to work and 
education for the persons with disabilities within the limits of its 
* Author
[2025] 2 S.C.R. 
1143
Anmol v. Union of India & Ors.
economic capacity and development – Persons with Disabilities 
(Equal Opportunities, Protection of Rights and Full Participation) Act, 
1995 was enacted for furtherance of this duty – After signing United 
Nations Convention on the Rights of Persons with Disabilities, 2008 
a more comprehensive RPwD Act was enacted in 2016 to further 
the principles enshrined in the Convention like respect for inherent 
dignity; individual autonomy including the freedom to make one’s 
own choices; non-discrimination; full and effective participation 
and inclusion in society; respect for difference and acceptance of 
persons with disabilities as part of human diversity and humanity; 
equality of opportunity and accessibility – Purposive interpretation 
of the RPwD Act has to be employed and therefore merely based 
on the quantification of the disability, a candidate will not forfeit 
his right to stake a claim for admission to the course of his or her 
choice – No classification can be overbroad – In Sunanda Bhandare 
Foundation v. Union of India, (2014) 14 SCC 383 it was held that 
in the matters of providing relief to those who are differently abled, 
the approach and attitude of the executive must be liberal and 
relief oriented and not obstructive or lethargic. [Paras 15-16, 19]
Graduate Medical Education Regulations (Amendment), 2019 
issued by National Medical Commission (‘NMC’) – Need for 
revision – Based on Communication from Ministry of Social 
Justice and Empowerment dated 25.01.2024 pursuant to 
directions in Bambhaniya Sagar Vasharambhai v. Union of 
India (Writ Petition (C) No. 856 of 2023) – Discussed:
Held: The Communication from Ministry of Social Justice and 
Empowerment mandated the review of regulations by the NMC 
to work out functional classifications and physical requirements 
consistent with the requirements of medical profession like the 
one prepared by Department of Personnel and Training (DoPT) 
w.r.t. civil servants. [Paras 17, 18, 22, 25, 45]
Concept of ‘Reasonable Accommodation’ – Explained keeping 
in mind the ratio in Omkar Ramchandra Gond v. Union of India 
& Ors., 2024 SCC OnLine SC 2860:
Held: In Omkar Ramchandra Gond it was held that – Revised 
regulations and guidelines which the National Medical Commission 
will issue shall have an inclusive attitude towards persons with 
disabilities from all categories, furthering the concept of reasonable 
accommodation recognized in the RPwD Act – Section 2(y) RPwD 
1144
[2025] 2 S.C.R.
Supreme Court Reports
Act defines ‘reasonable accommodation’ to mean necessary and
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