Orissa High Court Quashes Policy Denying NOC to In-Service Doctors for Sponsored DNB Admissions
Court says refusal violates equality under Article 14
Ruling strengthens rights of government doctors pursuing higher studies
By Our Legal Correspondent
New Delhi: January 22, 2026:
In a landmark decision, the Orissa High Court has struck down a controversial clause in the Odisha government’s 2022 policy that barred in-service medical officers from obtaining a No Objection Certificate (NOC) for admission to Sponsored DNB (Diplomate of National Board/ Post MBBS) courses. The court held that such denial was arbitrary, unreasonable, and unconstitutional, violating the equality guarantee under Article 14 of the Constitution of India.
The ruling, delivered by a division bench of Justice Manash Ranjan Pathak and Justice Mruganka Sekhar Sahoo, came in response to a petition filed by Dr. Subrat Jamadar, an Odisha Medical and Health Services (OMHS) officer, who was denied an NOC despite being eligible for centralized counselling conducted by the National Board of Examinations in Medical Sciences (NBEMS).
Case Background
- Petitioner: Dr. Subrat Jamadar, an in-service medical officer with NEET-PG 2024 All India Rank 87,721.
- Issue: Denial of NOC by the Odisha government for Sponsored DNB admission.
- Policy Clause: The 2022 state policy barred in-service doctors from applying for Sponsored DNB courses, while allowing them for other PG courses.
- Court’s View: The refusal was discriminatory since no intelligible differentia existed between DNB and Sponsored DNB candidates under the same service rules.
The High Court quashed the clause, allowing Dr. Jamadar and other in-service doctors to pursue Sponsored DNB admissions without arbitrary restrictions.
Court’s Observations
The bench made several critical observations:
- Violation of Article 14: Denying NOC only for Sponsored DNB admissions created unjustified discrimination.
- No intelligible differentia: Both DNB and Sponsored DNB candidates fall under the same service rules; treating them differently was unconstitutional.
- Right to education: In-service doctors cannot be denied opportunities for higher studies based on arbitrary policy distinctions.
- Policy quashed: The court struck down the discriminatory clause in Odisha’s 2022 policy, restoring equal rights for medical officers.
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Broader Implications
This ruling has far-reaching consequences for medical education and healthcare governance:
- Empowers in-service doctors: Government doctors can now pursue Sponsored DNB courses without fear of arbitrary denial.
- Strengthens equality: Reinforces constitutional guarantees of equal treatment under service rules.
- Boosts healthcare quality: More doctors will be able to specialize, improving medical services in public hospitals.
- Sets precedent: Other states with similar restrictive policies may face legal challenges.
Related Cases and National Context
- Delhi High Court (2026): Recently heard similar petitions regarding NOC denial for PG admissions, stressing fairness in opportunities.
- Other states: Maharashtra and Karnataka have faced disputes over rural service bonds and NOC policies for in-service doctors.
- National debate: The balance between service obligations and higher education opportunities remains a contentious issue across India.
Reactions
- Medical community: Welcomed the ruling as a victory for fairness and professional growth.
- Legal experts: Said the judgment strengthens constitutional protections against arbitrary state action.
- Policy analysts: Noted that while states aim to retain doctors in service, blanket bans on higher education are counterproductive.
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Conclusion
The Orissa High Court’s ruling that denying NOC to in-service doctors for Sponsored DNB admissions is arbitrary and unconstitutional marks a turning point in medical education policy. By quashing discriminatory clauses, the court has upheld the rights of government doctors to pursue specialization, reinforcing equality under Article 14.
This judgment not only benefits doctors in Odisha but also sets a precedent for similar disputes nationwide, ensuring that professional growth and healthcare quality are not compromised by arbitrary state policies.
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