Siddhant Mahajan and Ors. v. State of Rajasthan and Ors.; 2025 INSC 1458 - Revised BDS Course Regulations - Promissory Estoppel
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Revised BDS Course Regulations, 2007 - the minimum qualifying percentile for admission to the BDS course is 50th percentile in NEET for 45 candidates in the unreserved category, 40th percentile for SC/ST/OBC candidates and 45th percentile for candidates with locomotory disability of the lower limbs - The said can be reduced in accordance with the proviso attached to the sub-regulation 5(ii) of Regulation II of the 2007 Regulations, only when a sufficient number of candidates in the respective categories fail to secure the prescribed minimum cut-off marks for the concerned academic year- The power to undertake such a reduction in the qualifying percentile is only vested in the Central Government, to be exercised in consultation with the DCI- Such a power cannot be exercised by any other authority or the State Government. (Para 42)
Admissions - MBBS and BDS Courses - Admissions to MBBS and BDS courses in all government and private medical colleges are to be undertaken solely on the basis of NEET merit. (Para 40) The NEET examination functions as a mechanism which not only upholds the high standards of medical education across the country through its recognition of merit but also ensures a levelplaying field for medical aspirants. Consequently, all admissions to medical institutions must strictly conform to the standards and regulations prescribed for the conduct of NEET, so as to safeguard the primacy of merit. (Para 41)
Doctrine of promissory estoppel - The doctrine of promissory estoppel cannot be invoked to sustain an action taken in contravention of a statutory mandate. (Para 49)
Case Info
Key Details
- Case name and neutral citation: Siddhant Mahajan and Ors. v. State of Rajasthan and Ors.; 2025 INSC 1458.
- Coram: J.K. Maheshwari, J. and Vijay Bishnoi, J.
- Judgment date: 18 December 2025.
Caselaws and citations referred
- Sankalp Charitable Trust and Anr. v. Union of India and Ors., (2016) 7 SCC 487.
- Christian Medical College Vellore Association v. Union of India and Ors., (2020) 8 SCC 705.
- Harshit Agarwal and Ors. v. Union of India and Ors., (2021) 2 SCC 710.
- Rishabh Choudhary v. Union of India and Ors., (2017) 3 SCC 652.
- Maharishi Dayanand University v. Surjeet Kaur, (2010) 11 SCC 159.
- State of H.P. v. Himachal Institute of Engg. and Technology, (1998) 8 SCC 501.
- Abdul Ahad and Ors. v. Union of India and Ors., (2022) 18 SCC 108.
- Priya Gupta v. State of Chhattisgarh and Ors., (2012) 7 SCC 433.
- Deepa Thomas and Ors. v. Medical Council of India and Ors., (2012) 3 SCC 430.
- Saraswati Educational Charitable Trust and Anr. v. Union of India and Ors., (2021) 18 SCC 779.
- Rajiv Gandhi University of Health Sciences v. Bapuji Dental College and Hospital and Ors., SLP (C) Nos. 2597–2610/2015.
- Ebtesham Khatoon v. Union of India and Ors., 2025 SCC OnLine SC 380.
Statutes, regulations, and legal provisions referred
- Dentists Act, 1948; Section 20 (rule-making).
- Dentists (Amendment) Act/Ordinance, 2016; Section 10D (uniform entrance exam and proviso for 2016–17).
- Revised BDS Course Regulations, 2007; Regulation II(5)(ii) and its proviso (minimum percentile; Central Government’s power to lower cutoff in consultation with DCI).
- 5th Amendment Regulations, 2012 (substitution of Regulation II(5)).
- NEET UG framework and prospectus provisions (CBSE/NEET qualifying percentile).
- Article 142 of the Constitution of India (complete justice).
- Directive Principles and Fundamental Duties referenced in CMC Vellore: Articles 47, 46, and 51A(j).
- Articles 14, 19(1)(g), 21, 25, 26, 29(1), and 30 (in context of regulatory validity in CMC Vellore).
