Published on: 7th October 2026
Authored by: Md Imaran
Asian Law College
I. Case Details
Full Case Name: Anmol v. Union of India & Ors.
Citation: [2025] 2 S.C.R. 1142; 2025 INSC 256[1]
Court: Supreme Court of India
Bench: Two-Judge Bench
Date of Judgment: February 21, 2025[2]
Appeal No.: Civil Appeal No. 14333 of 2024[3]
II. Facts and Issues
Brief Facts:
The appellant, Anmol, a candidate with a locomotor disability, appeared for the National Eligibility cum Entrance Test (NEET-UG) 2024 Examination and secured a rank of 2462 in the Persons with Disabilities (PwD) category.[4] Despite his meritorious performance, his candidature for admission to the MBBS course was rejected by the National Medical Commission (NMC) on the ground that he did not satisfy the eligibility criterion under Appendix H-1 to the Graduate Medical Education Regulations (Amendment), which required medical aspirants to have “both hands intact.”[5]
This eligibility framework operated on a quantified disability threshold model, mandating rigid compliance with physical standards that excluded candidates with certain locomotor disabilities from medical education regardless of academic merit or functional capacity.[6] Aggrieved by the denial, Anmol approached the Supreme Court challenging the constitutional validity of the eligibility criteria.[7]
Legal Issues:
1. Whether the rigid eligibility criterion requiring medical aspirants to have “both hands intact” is constitutionally valid in light of the Rights of Persons with Disabilities (RPwD) Act 2016 and fundamental rights under the Constitution of India.
2. Whether the prescriptive eligibility criteria in Appendix H-1 to the Graduate Medical Education Regulations (Amendment) violate the principle of reasonable accommodation under the RPwD Act 2016.
3. Whether quantified disability thresholds and rigid physical standards adopted by the NMC are discriminatory and violative of Article 14 of the Constitution.[8]
III. Arguments
Petitioner’s Contentions:
The petitioner contended that the NMC’s rigid criteria failed to incorporate the principle of reasonable accommodation, which imposes a positive obligation on state and private entities to provide support to persons with disabilities to facilitate their participation in society.[9] Denying admission despite a qualifying NEET rank constituted a failure to provide such accommodation.[10]
It was submitted that the “both hands intact” rule operated as a blanket exclusion bearing no rational nexus to the objective of producing competent medical professionals.[11] The criterion failed the test of reasonable classification under Article 14 because it ignored functional capabilities.[12] The petitioner argued that eligibility should be determined through a functional assessment of abilities rather than prescriptive physical metrics, in alignment with the spirit of the RPwD Act 2016.[13]
Respondent’s Contentions:
The NMC submitted that the “both hands intact” requirement was necessary to ensure patient safety and maintain standards of medical care, as medical professionals must be physically capable of performing clinical and surgical procedures.[14]
The respondent argued that classifying candidates based on physical fitness constituted a valid classification under Article 14 based on intelligible differentia with a rational nexus to medical training objectives.[15] The NMC further argued that as a statutory expert body, its prescribed eligibility standards were entitled to judicial deference.[16]
IV. Judgment and Ratio Decidendi
Judgment:
The Supreme Court allowed the appeal and quashed the NMC’s eligibility criterion requiring “both hands intact,” holding that rigid reliance on quantified disability thresholds was unconstitutional.[17] The Court issued a specific direction to create a seat for Anmol at a medical college near his residence.[18]
Ratio Decidendi:
1. Positive Obligation of Reasonable Accommodation: The principle of reasonable accommodation captures the positive obligation of the State and private entities to provide support to persons with disabilities to facilitate full participation.[19] Fundamental rights under Articles 14, 19, and 21 remain incomplete without affirmative support.[20]
2. Social Model of Disability and Inclusion: Disability is a social construct, requiring the affirmative creation of supportive conditions. Exclusion negates individual dignity, whereas reasonable accommodation respects personal worth and inclusion.[21]
3. Functional Assessment Over Rigid Thresholds: Eligibility for medical education must be evaluated on functional capability rather than rigid physical criteria. The “both hands intact” rule was rooted in ableism and violated Article 41 of the Constitution.[22]
4. Individualized Accommodation: Mandated accommodation must be tailored to individual disability needs; failure to meet individual requirements breaches the norm of reasonable accommodation.[23]
V. Critical Analysis
Jurisprudential Significance:
The judgment in Anmol v. Union of India & Ors. marks a significant shift in Indian disability jurisprudence by moving from a medical model of disability to a social model that recognizes societal barriers as the primary source of disablement.[24] The Court’s reliance on reasonable accommodation advances substantive equality under Articles 14, 15, 21, and 41 of the Constitution.[25]
Consistency with Precedents:
The decision extends the framework articulated in Vikash Kumar v. UPSC[26] from civil service examinations to professional medical education. It also aligns with K.S. Puttaswamy v. Union of India[27] by reinforcing decisional autonomy and dignity under Article 21.[28]
Progressive Interpretation:
Prioritizing functional assessment over rigid physical metrics reflects an understanding that clinical competence is not defined by physical attributes alone.[29] This approach aligns with international norms under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).[30] Directing the creation of a medical seat ensured tangible relief to the appellant.[31]
Potential Implications:
The ruling expands access to medical education for candidates with locomotor disabilities and establishes a precedent for other regulated professions.[32] Regulatory bodies, including the NMC, must revise eligibility criteria to replace rigid physical standards with functional assessment mechanisms.[33]
Critiques and Limitations:
While progressive, directing an individual seat allocation does not offer a systemic framework for future cases.[34] The judgment also leaves open the specific parameters for functional assessments, which may require further judicial clarification during administrative implementation.[35]
VI. Conclusion
Anmol v. Union of India & Ors. is a landmark judgment in Indian disability rights jurisprudence.[36] By striking down the “both hands intact” rule and enforcing reasonable accommodation, the Supreme Court reinforced constitutional guarantees of equality and dignity under Articles 14, 21, and 41.[37]
References
[1] Anmol v. Union of India & Ors., [2025] 2 S.C.R. 1142; 2025 INSC 256.
[2] Anmol, 2025 INSC 256, ¶ 1.
[3] Anmol v. Union of India & Ors., Civil Appeal No. 14333 of 2024.
[4] Anmol, 2025 INSC 256, ¶ 3.
[5] Graduate Medical Education Regulations (Amendment), Appendix H-1.
[6] Rights of Persons with Disabilities Act, No. 49 of 2016, INDIA CODE (2016).
[7] Anmol, 2025 INSC 256, ¶ 5.
[8] INDIA CONST. arts. 14, 21, 41.
[9] Rights of Persons with Disabilities Act, No. 49 of 2016, § 3, INDIA CODE (2016).
[10] Anmol, 2025 INSC 256, ¶ 8.
[11] INDIA CONST. art. 14.
[12] Anmol, 2025 INSC 256, ¶ 10.
[13] Rights of Persons with Disabilities Act, No. 49 of 2016, § 16, INDIA CODE (2016).
[14] Anmol, 2025 INSC 256, ¶ 12.
[15] INDIA CONST. art. 14.
[16] Anmol, 2025 INSC 256, ¶ 14.
[17] Id. at ¶ 20.
[18] Id. at ¶ 22.
[19] Rights of Persons with Disabilities Act, No. 49 of 2016, § 2(h), INDIA CODE (2016).
[20] INDIA CONST. arts. 14, 19, 21.
[21] Anmol, 2025 INSC 256, ¶ 25.
[22] INDIA CONST. art. 41.
[23] Anmol, 2025 INSC 256, ¶ 28.
[24] Id. at ¶ 30.
[25] INDIA CONST. arts. 14, 15, 21, 41.
[26] Vikash Kumar v. UPSC, (2021) 5 SCC 370.
[27] K.S. Puttaswamy v. Union of India, (2017) 10 SCC 1.
[28] INDIA CONST. art. 21.
[29] Anmol, 2025 INSC 256, ¶ 33.
[30] UN Convention on the Rights of Persons with Disabilities, Dec. 13, 2006, 2515 U.N.T.S. 3.
[31] Anmol, 2025 INSC 256, ¶ 35.
[32] Id. at ¶ 38.
[33] Id. at ¶ 40.
[34] Id. at ¶ 42.
[35] Id. at ¶ 44.
[36] Anmol v. Union of India & Ors., 2025 INSC 256.
[37] INDIA CONST. arts. 14, 21, 41.
