Bench: Justice Prathiba M. Singh
Case No.: W.P.(C) 1712/2025
Case Title: Sahil Arsh v. National Medical Commission & Ors.
Date of Judgment: 4 February 2026
Background
The petition before the Delhi High Court was filed by a medical student with a disability who challenged certain regulatory restrictions imposed by the National Medical Commission (NMC) that limited the ability of persons with disabilities to pursue medical education. The petitioner contended that the eligibility criteria and institutional practices adopted by medical authorities did not adequately account for the needs of students with disabilities.
According to the petitioner, despite the statutory protections provided under the Rights of Persons with Disabilities Act, 2016, several medical institutions continued to apply rigid eligibility requirements that effectively excluded candidates with disabilities from pursuing medical education or completing their training on equal terms. The petitioner argued that such practices were inconsistent with the principle of reasonable accommodation mandated by the RPwD Act.
The matter therefore raised an important question regarding the obligations of regulatory bodies governing professional education. Specifically, the Court was required to consider whether professional standards could be interpreted in a manner that excluded persons with disabilities or whether institutions must adapt their systems to ensure inclusive participation.
Key Observations
The Delhi High Court emphasised that professional education, including medical education, must be governed by the principles of equality, accessibility and reasonable accommodation recognised under the RPwD Act. The Court observed that regulatory bodies cannot frame or enforce rules that have the effect of systematically excluding persons with disabilities from professional courses.
Justice Prathiba M. Singh noted that the purpose of disability legislation is to ensure that educational institutions adopt inclusive practices that enable students with disabilities to participate effectively. This includes not only physical accessibility but also modifications in academic procedures, evaluation systems and institutional support mechanisms.
The Court further observed that professional competence should not be assessed through rigid assumptions about disability. Instead, institutions must examine whether reasonable accommodations and assistive technologies can enable students with disabilities to perform the essential functions required in the profession.
Importantly, the Court emphasised that regulatory frameworks governing medical education must be interpreted in a manner that advances the objective of inclusion rather than reinforcing outdated perceptions about the capabilities of persons with disabilities.
Directions Issued
• The Court directed the National Medical Commission to reconsider the petitioner’s case in light of the principles of reasonable accommodation under the RPwD Act.
• Authorities were instructed to ensure that regulatory guidelines governing medical education are consistent with the statutory rights of persons with disabilities.
• The Court emphasised that institutions must adopt inclusive policies that enable students with disabilities to participate effectively in professional education.
Commentary
The judgment represents an important development in the evolving discourse on disability rights in professional education. Historically, certain professions—including medicine—have been governed by rigid eligibility criteria that often excluded persons with disabilities based on assumptions about their abilities.
However, contemporary disability rights law recognises that such exclusion frequently reflects institutional barriers rather than inherent limitations. Advances in assistive technologies, adaptive learning systems and inclusive teaching methods have significantly expanded the possibilities for persons with disabilities to participate in professional fields.
By emphasising the obligation of regulatory bodies to incorporate reasonable accommodation into professional education frameworks, the Delhi High Court reaffirmed the transformative vision underlying the RPwD Act. The statute seeks not merely to remove formal barriers but to reshape institutional practices so that diversity becomes a normal and expected feature of educational environments.
The decision also signals a broader shift in judicial thinking. Rather than treating disability as a ground for exclusion from demanding professions, courts increasingly recognise that institutions must adapt their structures to accommodate diverse forms of participation. In doing so, the judgment contributes to the development of a more inclusive model of professional education in India.
Read the judgement [PDF 560KB]
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