Beyond “Both Hands Intact”: Supreme Court Rejects Ableist Approach to Medical Education in Anmol Vs UOI

Court: Supreme Court of India
Bench: Justice B.R. Gavai and Justice K. V. Viswanathan 
Case No. : Civil Appeal No. 14333 of 2024
Case Title:  Anmol v. Union of India & Ors.
Date of Judgement: 21 February 2025

Overview:

The Supreme Court has once again affirmed that disability cannot be treated as a proxy for professional incompetence. In Anmol v. Union of India, the Court held that medical aspirants with disabilities must be assessed on functional competence, with reasonable accommodation and assistive technology, rather than through rigid assumptions about their bodies.

Background

Anmol, an aspiring medical student, had secured rank 2462 in the PwD category in NEET-UG 2024 and had a 58% multiple disability comprising locomotor and speech and language disabilities. Despite meeting the eligibility threshold for the PwD quota, a Disability Assessment Board declared him ineligible for the MBBS course.

The principal barrier was the regulatory requirement that candidates with locomotor disabilities should have “both hands intact, with intact sensations, sufficient strength and range of motion.”

The Supreme Court found this approach legally unsustainable.

From impairment to functional competence

The Court emphasised that a disability assessment cannot end with the percentage of disability. Drawing upon its recent decisions in Omkar Ramchandra Gond v. Union of India and Om Rathod v. Director General of Health Services, it reiterated that a candidate must be assessed to determine whether they can actually pursue the particular course, including with reasonable accommodation and assistive technology.

The Court was particularly critical of an approach under which Disability Assessment Boards become, in its words, “monotonous automations” that look at quantified disability and reject a candidate. Boards must instead examine whether the disability will actually prevent the candidate from pursuing the course.

This distinction is crucial. Functional competency focuses on the outcome that must be achieved, rather than insisting that every candidate achieve it in the same physical manner.

Reasonable accommodation is central—not an afterthought

The judgment reiterates the broad meaning of reasonable accommodation under Section 2(y) of the RPwD Act, 2016.

Accommodation is not limited to providing an assistive device. It may require modifications and adjustments that enable a person with disability to participate equally. The Court stressed that accommodation must be responsive to the individual needs of the person, and that there can be no “one size fits all” approach.

In Anmol's case, a separate assessment by Dr. Satendra Singh examined his actual functional abilities and considered possible clinical accommodations and assistive technologies. The assessment included simulated testing of several medical procedures, including suturing, handling syringes, making incisions, CPR and catheterisation.

The assessment concluded that Anmol could pursue the MBBS course with appropriate accommodations and assistive technology. The Supreme Court accepted this assessment.

“Both hands intact” has no place in disability-inclusive regulation

The Court expressly rejected the requirement of having “both hands intact”, holding that it failed to provide for individual functional assessment and was inconsistent with Article 41 of the Constitution, the UN Convention on the Rights of Persons with Disabilities and the RPwD Act.

The Court stated:

“A prescription such as ‘both hands intact’ reeks of ableism and has no place in a statutory regulation.”

This is perhaps the most significant aspect of the judgment. A professional standard cannot simply reproduce the physical characteristics of the non-disabled majority and treat them as prerequisites for competence.

Expert opinion must also comply with the law

The Court clarified that it was not substituting its medical opinion for that of the experts. Courts are not medical boards. However, courts have both the jurisdiction and duty to ensure that the assessment process complies with constitutional and statutory requirements.

A negative assessment must therefore be reasoned, transparent and based on functional assessment. In the present case, the five-member AIIMS report did not adequately explain how Anmol had failed the functional assessment or why accommodation could not address the identified limitations.

The larger principle

The judgment reinforces a growing line of Supreme Court decisions moving disability law away from presumed incapacity towards functional ability, reasonable accommodation and substantive equality.

The correct question is not:

“Does this person have the physical characteristics traditionally associated with a doctor?”

It is:

“What are the essential competencies of the profession, can this person acquire and demonstrate them, and what reasonable accommodations may be required to enable equal participation?”

That shift is important not only for medical education, but for professional education and employment more broadly.

The Supreme Court ultimately confirmed Anmol's admission to Government Medical College, Sirohi, Rajasthan, and directed that the status of the revised NMC guidelines be placed before the Court.

Anmol therefore adds another important proposition to Indian disability jurisprudence: disability is not incompetence, and an assessment that does not meaningfully consider function, accommodation and assistive technology risks converting a professional eligibility test into a test of conformity with an able-bodied norm.

Read the judgement in Anmol Vs. UOI dated 21 Feb 2025