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In a recent landmark ruling, the Karnataka High Court has upheld the National Medical Commission’s (NMC) regulation capping the number of attempts for clearing first-year MBBS subject examinations at four. This decision reaffirms the regulatory framework designed to maintain stringent academic standards in medical education across India and echoes similar rulings by other High Courts, including the Delhi High Court. The ruling highlights the judiciary’s stance that no court can override or pass orders inconsistent with medical education regulations laid down by statutory authorities.
On September 25, 2025, the Karnataka High Court bench headed by Justice R. Devdas dismissed a plea by an MBBS student seeking permission for a fifth attempt at the biochemistry examination, which she had yet to clear. The student, Miss Nishat R. Kolyal of Dr. Ambedkar Medical College and Hospital, Bengaluru, challenged the regulatory cap that permits only four attempts to clear each subject in the first professional part of the MBBS course. The court ruled that adherence to the regulations set by the NMC and Rajiv Gandhi University of Health Sciences (RGUHS) is mandatory and that the petition seeking relief was untenable in law.
Key Findings and Rulings
The Karnataka High Court emphasized that the NMC regulations are binding and that courts lack jurisdiction to alter such academic rules. Justice Devdas stated, “No Court can pass an order contrary to the Regulations and norms prescribed by the university.” The court further noted that the petitioner had already exhausted the permissible four attempts, and allowing an additional chance would violate the established framework.
Similar sentiments were echoed earlier by the Delhi High Court in a November 2022 ruling, which rejected petitions from students seeking more than four attempts to pass the first-year MBBS exams. The Delhi bench clarified that the four-attempt limit was not arbitrary but intended to ensure academic rigor and uphold the profession’s sanctity, given the critical role doctors play in public health.
Expert Commentary
Dr. Rajesh Sharma, a senior education policy expert and former member of the NMC, commented, “The regulation limiting attempts to four is aimed at maintaining high standards in medical training. While it may seem stringent, it ensures that only candidates with adequate competence progress. This is crucial for safeguarding public health since underqualified practitioners pose risks to patient safety.”
Education law specialist Advocate Meera Joshi added, “The judiciary’s consistent upholding of these regulations underscores the policy validity and constitutionality of attempt limits. Courts recognize that medical qualifications are privileges contingent on meeting rigorous academic standards.”
Context and Background
The National Medical Commission introduced these regulations as part of the Competency-Based Medical Education (CBME) curriculum reforms, emphasizing quality over quantity in medical training. According to the NMC Graduate Medical Education regulations amended in 2019, no student is allowed more than four attempts to clear any first professional university examination. The CBME framework mandates this attempt cap to encourage timely completion and mastery of critical subjects.
This policy contrasts with the National Eligibility cum Entrance Test (NEET) for medical college admissions, where currently there is no cap on the number of attempts. NEET regulations allow unlimited attempts, enabling aspirants multiple opportunities to enter medical education. However, once admitted, the NMC insists on maintaining academic discipline in professional examinations to ensure competence.
Implications for Public Health and Medical Education
The ruling signals a message to students and educational institutions alike: adherence to established academic standards is crucial. The limitation on exam attempts protects public health by helping to ensure that only capable individuals become licensed medical practitioners. It prevents prolonged academic delays and ensures a steady supply of qualified doctors.
From a policy standpoint, such regulations encourage students to prepare adequately, focus on core competencies, and maintain the integrity of the medical education system. It also avoids flooding the medical workforce with under-prepared graduates, which could undermine healthcare quality in the long run.
Potential Limitations and Counterarguments
Some critics argue that rigid attempt limits can disproportionately impact students facing genuine hardships, such as health issues or learning difficulties. They advocate for more flexible, compassionate approaches, including provisions for additional “mercy attempts” in exceptional cases.
However, courts have so far maintained that fairness to the individual cannot override the broader interest of maintaining educational standards and healthcare safety. While these rules may seem harsh, they are designed after careful deliberation of public interest and the ethical mandate of medical training.
Practical Takeaways for Students and Educators
For aspiring medical students and educators, the ruling underscores the importance of early and consistent academic performance. Students should view the four-attempt limit as an imperative for diligent study and timely clearing of exams. Educational institutions must ensure robust student support, counseling, and remediation programs to help learners meet these expectations within the attempt limit.
Medical aspirants should also understand the regulatory environment fully before enrolment and seek academic guidance to avoid exhausting permitted attempts prematurely.
Medical Disclaimer
Medical Disclaimer: This article is for informational purposes only and should not be considered medical advice. Always consult with qualified healthcare professionals before making any health-related decisions or changes to your treatment plan. The information presented here is based on current research and expert opinions, which may evolve as new evidence emerges.
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