Soumya Ranjan Panda vs. Subhalaxmi Dash 2026 INSC 488- Medical College Admissions
Legal Maxim -Commodum ex injuria sua nemo habere debet - No one should derive a benefit from their own wrong. [Context: The case concerns MBBS students originally admitted to Sardar Rajas Medical College (SRMCH), Odisha, whose academic future was jeopardized when MCI/NMC found serious deficiencies and the college’s renewal was denied, forcing their relocation to three private “transferee” colleges pursuant to Supreme Court orders. The present judgment no longer examines the High Court’s original relocation directions but resolves who must bear the financial burden of fees for the education imparted by the transferee colleges, holding that students cannot enjoy a permanent benefit of low, government‑rate fees when they had knowingly joined a private college charging higher fees, and that SRMCH/Selvam Trust, as the defaulting institution, must bear the primary liability. The Court directs that about Rs. 10 crores in bank guarantees given by the Selvam Trust to MCI/NMC and Rs. 2 crores deposited in the Supreme Court be released in equal shares to the three transferee colleges, and permits those colleges to approach NMC to recover any remaining shortfall (calculated on SRMCH’s fee scale) from the passed‑out students, while ensuring students receive their course‑completion documents upon complying with the determined fee liability.]
Case Info
Case name: Soumya Ranjan Panda & Ors. v. Subhalaxmi Dash & Ors.
Neutral citation: 2026 INSC 488
Coram: Vikram Nath, J. and Sandeep Mehta, J.
Judgment date: 14 May 2026, New Delhi
Caselaws and citations referred:
- Priya Gupta v. State of Chhattisgarh, (2012) 7 SCC 433
- Hind Charitable Trust & Ors. v. Union of India & Ors., W.P.(C) No. 469 of 2014, interim orders dated 18.09.2014 and 24.09.2014 (quoted and applied)
- Sardar Rajas Medical College v. Union of India, W.P.(C) No. 681 of 2014 (dismissed on 08.08.2014)
AI Generated Summary
## Soumya Ranjan Panda vs. Subhalaxmi Dash — C.A. No. 7861-7862/2026
**Supreme Court of India | Decided: 14 May 2026 | Bench: Vikram Nath & Sandeep Mehta JJ.** --- ### 1. Plain-Language Summary Sardar Rajas Medical College (SRMCH) in Odisha admitted two batches of MBBS students (2013–14 and 2014–15), but was subsequently found to have serious deficiencies in infrastructure and faculty by the Medical Council of India, which led to denial of renewal of its recognition. The Supreme Court had earlier stepped in to relocate approximately 122 affected students to three recognised private colleges in Bhubaneswar, allowing them to complete their degrees — but only at heavily subsidised government-rate fees as an emergency measure. The core question left unresolved was: who pays the difference between those low fees and the actual fees charged by the three private colleges that took the students in? The Court's final ruling is that the primary financial burden falls on the defaulting trust (Selvam Educational and Charitable Trust) that ran SRMCH, directing around ₹12 crores held across a bank guarantee with the MCI and a court deposit to be paid out to the three colleges — and putting the students on notice that they too must pay their fair share of outstanding fees. --- ### 2. Key Legal Questions Decided **a) What fee rate applies to the transferred students?**
The Court held that since there was no evidence that any of the three transferee colleges had vacant Government-quota seats, all transferred students must be treated as occupying private/management quota seats, and the fee structure applicable to those seats applies. **b) Was it unjust enrichment for students to benefit from government-rate fees throughout?**
The Court held that allowing students — who had originally chosen and contracted to pay private college fees at SRMCH — to permanently benefit from government-rate fees would amount to unjust enrichment, invoking the Latin maxim *commodum ex injuria sua nemo habere debet* (no one should derive benefit from their own wrong), which it applied against both the students and the defaulting institution. **c) Who bears the primary financial liability?**
The Court found that the primary liability must be fastened upon SRMCH/Selvam Trust, as the entire crisis was caused by its failure to maintain the requisite standards, and it had also failed to refund excess fees already collected. --- ### 3. Notable Reasoning & Principles - **Balancing equity in judicial intervention:** The Court acknowledged the extraordinary situation where its own interim orders had created the subsidised fee regime as an emergency measure to protect students' academic careers, but stressed that such interim arrangements cannot translate into a permanent windfall for those students. - **Undertakings given by students are binding:** The transferee colleges had obtained undertakings from students at the time of issuing course-completion documents, acknowledging that fee liability remained pending before the Court. The Court held that students who have completed their courses cannot now escape that liability. - **Directions for disbursement:** The approximately ₹10 crore bank guarantee furnished by Selvam Trust with the MCI/NMC, and the ₹2 crore (plus accrued interest, now ~₹3.58 crore) deposited in the Court Registry, are to be divided equally among the three transferee colleges — KIMS, IMS & SUM Hospital, and Hi-Tech Medical College — within three months. - **Residual student liability:** Since the total funds available (~₹14 crore) still fall short of the approximately ₹16.2 crore owed at SRMCH rates, the transferee colleges are permitted to approach the NMC with details of individual shortfalls, and the NMC is expected to assist in recovering the remaining dues from the passed-out students. Students who settle their dues are entitled to receive their academic certificates forthwith. - **Protection of future rights:** The Court was careful to note that its observations do not prejudice any pending regulatory or legal proceedings involving Selvam Trust/SRMCH.