Mere Registration on Another State’s NEET Counselling Portal Without Completing Application or Claiming Quota Benefits Cannot Disqualify Candidate from Punjab MBBS State Quota; Punjab and Haryana High Court Quashes Debarment
Case Name: Rayna Nag v. State of Punjab and Others
Date of Judgment: 29 September 2026
Citation: CWP-28493-2026
Bench: Hon’ble Mr. Justice Suvir Sehgal and Hon’ble Mr. Justice Rajesh Gaur
Held: The Punjab and Haryana High Court held that mere creation of a login ID, preliminary registration or entry of personal particulars on the medical admission portal of another State or Union Territory, without completing the prescribed application process or submitting the requisite statutory declarations, cannot by itself constitute a claim for admission under that State’s quota. A candidate who withdraws such incomplete registration before publication of the provisional merit list and neither participates in counselling nor derives any benefit from the other State’s quota cannot be disqualified from consideration under the Punjab State Quota merely on the basis of that registration.
Interpreting Clause 18 of the Punjab MBBS/BDS admission notification, the Court held that the prohibition against claiming, seeking or availing State Quota eligibility in another State or Union Territory must be applied in the context of its underlying objective rather than mechanically. The provision seeks to prevent candidates from simultaneously competing under multiple State Quotas and thereby securing an unfair advantage. An incomplete registration, voluntarily withdrawn before the admission process progresses to consideration of candidature, does not attract the disqualification where no substantive claim to the other quota has been made.
The Court reiterated that conditions contained in an admission prospectus or notification ordinarily bind both candidates and admission authorities and must be applied uniformly. However, the authorities must determine whether the conduct attributed to a candidate actually falls within the prohibition prescribed by the relevant condition.
Accordingly, the Court held that debarring an otherwise eligible NEET candidate from admission against the 85% Punjab State Quota solely because she had initiated, but not completed, registration on the Chandigarh medical counselling portal was legally unsustainable.
Summary: The Punjab and Haryana High Court, in a judgment delivered by a Division Bench comprising Justice Suvir Sehgal and Justice Rajesh Gaur, examined whether a candidate who had initiated registration for MBBS admission under the Union Territory of Chandigarh Quota, but withdrawn her candidature before completing the application process, could be debarred from consideration under the 85% Punjab State Quota for the same academic session.
The writ petition was filed by Rayna Nag, challenging the public notice dated 28.08.2026 issued by Baba Farid University of Health Sciences, Faridkot (BFUHS), to the extent that it disqualified her from consideration for admission to the MBBS course under the Punjab State Quota for the academic session 2026–27. The petitioner also sought a consequential direction requiring the University to consider her candidature in accordance with her NEET (UG) 2026 merit.
The petitioner had appeared in NEET (UG) 2026 and secured 548 marks out of 720. Her mother, an ETT teacher, had been posted at Jawaharpur, Punjab, since 2013. Claiming eligibility under the Punjab State Quota, the petitioner registered with BFUHS pursuant to the admission notification dated 10.07.2026. Her name was included in the provisional merit list prepared by the University.
Meanwhile, Government Medical College and Hospital, Sector 32, Chandigarh (GMCH), issued its prospectus for admission to medical courses for the academic session 2026–27 on 13.08.2026. The petitioner created a login ID on the GMCH admission portal and entered certain particulars for the purpose of registration under the Chandigarh quota.
However, before publication of the first provisional merit list by GMCH, the petitioner submitted a communication dated 19.08.2026 withdrawing her candidature from the Chandigarh admission process. In the provisional combined merit list published by GMCH on 20.08.2026, her name appeared at serial number 110 with the specific observation that she was ineligible because her candidature had been withdrawn and the prescribed appendices had not been submitted.
The petitioner subsequently informed BFUHS of these circumstances through an email dated 26.08.2026. Notwithstanding the withdrawal, BFUHS issued the impugned public notice dated 28.08.2026, debarring her from consideration against the 85% Punjab State Quota on the ground that she had also applied for admission under the Chandigarh quota.
The State of Punjab and BFUHS defended the decision by relying upon Clause 18 of the admission notification. The provision required candidates and their parents or guardians to submit a sworn declaration confirming that the candidate had claimed eligibility and sought consideration under the Punjab State Quota alone and had not claimed, sought or availed State Quota benefits in any other State or Union Territory for the same academic session.
Clause 18 further prohibited submission of any application, affidavit, undertaking, declaration or other document claiming domicile, residence or similar eligibility for admission under the State Quota of another State or Union Territory. It also contemplated cancellation of candidature or admission where a candidate was found to have sought or claimed such benefits or furnished false or misleading declarations.
The respondents contended that the petitioner’s subsequent withdrawal could not erase the fact that she had initially sought consideration under the Chandigarh quota. BFUHS further submitted that the disqualification had been imposed upon receiving a communication from GMCH identifying candidates who had registered under both Chandigarh and Punjab State Quotas.
During the pendency of the proceedings, the petitioner was allotted a government quota seat in the General Category at Punjab Institute of Medical Sciences, Jalandhar, in compliance with an interim order passed by the High Court. The allotment remained subject to the final outcome of the writ petition.
GMCH, in its status report filed through its Director-Principal, acknowledged that the petitioner had submitted a request for withdrawal of her candidature on 19.08.2026 and that a decision declaring her ineligible had been recorded on the same day.
Examining the rival submissions, the Division Bench first reiterated the settled principle that conditions prescribed in an admission prospectus or notification are ordinarily binding upon both the candidates and the admission authorities. Referring to its earlier decision in Japuji Kaur Bains v. Union Territory of Chandigarh and Others, Law Finder Docket ID #2982538, the Court emphasised that admission conditions must be uniformly applied.
The central issue, however, was whether the petitioner’s incomplete registration on the GMCH portal amounted to claiming, seeking or availing the benefit of State Quota eligibility in another jurisdiction within the meaning of Clause 18.
Upon examining the record, the High Court noted that although the petitioner had created a login ID and entered certain details on the Chandigarh portal, she had neither completed the application form nor uploaded the documents and certificates necessary for claiming admission under the Chandigarh quota.
The Court further observed that the petitioner had not furnished the prescribed undertaking or affidavit relating to residence or State Quota eligibility before GMCH. The procedure for submission of a valid application, as contemplated by the GMCH prospectus, had therefore remained incomplete.
Significantly, the petitioner had withdrawn her candidature before publication of the provisional merit list. The GMCH merit list itself recorded the withdrawal and non-submission of the required appendices. The Court noted that the petitioner had not participated in counselling conducted by GMCH, had not been considered for allotment of a seat under the Chandigarh quota and had derived no advantage whatsoever from the registration.
The Division Bench consequently examined the purpose and scope of Clause 18. It observed that the prohibition was intended to prevent candidates from simultaneously competing under the State Quotas of two different States or Union Territories, thereby obtaining an unfair advantage over other candidates seeking admission under the respective quotas.
The Court held that the expression concerning claiming, seeking or availing State Quota eligibility must be interpreted in its proper context, and mere creation of a login ID or submission of preliminary particulars, without completing the application or furnishing the required declaration, cannot be equated with an actual claim for a seat under another State Quota.
The Bench emphasised that the petitioner had abandoned the Chandigarh admission process before her candidature could be considered and had elected to pursue admission under the Punjab State Quota alone. In these circumstances, her conduct did not attract the prohibition envisaged under Clause 18.
The High Court rejected the mechanical application of the disqualification clause by BFUHS. It held that the incomplete registration on the GMCH portal did not establish that the petitioner had claimed or availed the benefit of State Quota eligibility in Chandigarh in the manner contemplated by the notification.
Accordingly, the Court concluded that the decision to debar the petitioner from consideration against the 85% Punjab State Quota, solely on the basis of her incomplete and subsequently withdrawn Chandigarh registration, could not be sustained in law.
Decision: The Punjab and Haryana High Court allowed the writ petition and quashed the public notice dated 28.08.2026 issued by BFUHS, insofar as it debarred petitioner Rayna Nag from consideration for admission against the 85% Punjab State Quota for the MBBS course during the academic session 2026–27.
The Court held that the petitioner had not completed her application under the Chandigarh quota, had not submitted the required declarations or supporting documents, had withdrawn her candidature before publication of the provisional merit list and had neither participated in counselling nor obtained any benefit under the Chandigarh quota.
Consequently, the prohibition contained in Clause 18 of the Punjab admission notification was held inapplicable to her circumstances.
BFUHS was directed to forthwith consider the petitioner for admission to the MBBS course against the seat already allocated to her under the 85% Punjab State Quota.