In an important ruling reaffirming the principles of judicial discipline and administrative neutrality, the Kerala High Court has held that a quasi-judicial authority cannot maintain an appeal against a judgment that sets aside its own decision. The Court ruled that such an authority cannot be considered an “aggrieved person” merely because its order has been interfered with by a superior court.
The judgment was delivered on 31 January 2026 by a Division Bench comprising Justice Anil K. Narendran and Justice Muralee Krishna S., dismissing a writ appeal filed by the Admission Supervisory Committee for Medical Education, Kerala on the ground of non-maintainability.
Background of the Case
The case arose out of a dispute relating to admission to a BAMS course (Bachelor of Ayurvedic Medicine and Surgery) for the academic year 2023–2024.
The first respondent was a NEET (UG)–2023 candidate who secured admission to the BAMS course at Santhigiri Ayurveda Medical College under the OBC category, through a stray vacancy. His eligibility was based on his claim of belonging to the Chakkala Nair community, which was included in the OBC list through a Government Order dated 11 September 2023.
Although the candidate’s SSLC certificate mentioned his community as “Hindu Nair”, the Tahsildar later issued a clarification certificate stating that the correct community was “Hindu Chakkala Nair”. This correction was officially published in the Kerala Gazette, and the candidate was also issued non-creamy layer and caste certificates.
Role of the Admission Supervisory Committee
The Admission Supervisory Committee, constituted under the Kerala Medical Education (Regulation and Control of Admission to Private Medical Educational Institutions) Act, 2017, is empowered to regulate and supervise admissions to private medical institutions in the State.
When the college principal sought approval of the candidate’s admission, the Committee withheld approval and later passed orders disapproving and cancelling the admission granted under the OBC category.
Aggrieved by this decision, the candidate approached the Kerala High Court by filing a writ petition under Article 226 of the Constitution.
Decision of the Single Judge
By judgment dated 30 January 2025, the learned Single Judge of the High Court:
- Set aside the orders passed by the Admission Supervisory Committee
- Held that the candidate was eligible for admission under the OBC category
- Relied upon the Government Order and caste certificates produced by the candidate
The Court found no legal infirmity in the candidate’s admission and directed that it be approved.
Writ Appeal by the Committee
Following the adverse judgment, the Admission Supervisory Committee itself filed a writ appeal challenging the order of the Single Judge.
This led to the central legal issue before the Division Bench:
Whether a quasi-judicial authority can be treated as an “aggrieved person” entitled to maintain a writ appeal against a judgment setting aside its own quasi-judicial decision?
Arguments Before the Court
Candidate’s Contentions
The candidate argued that:
- The Committee was a quasi-judicial adjudicatory body
- Such authorities cannot defend or challenge their own decisions before superior courts
- The Committee was not an aggrieved party, as it did not suffer any legal injury
- Reliance was placed on established precedents discouraging adjudicatory bodies from litigating to uphold their own orders
Committee’s Contentions
The Committee contended that:
- It had a statutory duty to ensure fair, transparent, and lawful admissions
- Denial of the right to appeal would result in injustice and administrative failure
- It was justified in challenging the Single Judge’s decision to protect the integrity of the admission process
Findings of the Kerala High Court
After examining the statutory scheme and relevant precedents, the Division Bench rejected the Committee’s appeal as not maintainable.
Nature of the Committee’s Powers
The Court noted that:
- The Committee is constituted under Section 3 of the 2017 Act
- Under Section 8, it is empowered to inquire into admissions and take action
- For such inquiries, the Committee is vested with powers of a civil court
These features clearly establish that the Committee performs adjudicatory and quasi-judicial functions, not administrative or executive ones.
Who Is an “Aggrieved Person”?
The Court emphasised that:
- Section 12 of the Act provides a statutory right of appeal to persons aggrieved by the Committee’s orders
- Such aggrieved persons are always third parties—students, institutions, or stakeholders affected by the decision
- The Committee itself, being the decision-maker, cannot be considered an aggrieved party
The Court clarified that merely being arrayed as a respondent in a writ petition does not confer the status of an aggrieved person.
Principle of Judicial Discipline
Relying on settled law, the Bench reiterated that:
A quasi-judicial authority cannot challenge an order passed by a superior court interfering with its decision.
Allowing such appeals would undermine:
- Judicial discipline
- Institutional neutrality
- The independence of adjudicatory bodies
The Court warned that permitting such appeals would lead to an “anomalous situation”, where quasi-judicial authorities would routinely file appeals whenever their decisions are set aside.
Final Decision
Holding that the Admission Supervisory Committee is not an aggrieved person, the Division Bench:
- Dismissed the writ appeal as non-maintainable
- Declined to examine the merits of the candidate’s admission
- Reaffirmed that adjudicatory authorities must maintain neutrality and restraint
Significance of the Judgment
This ruling is significant in the context of administrative law and judicial review because it:
- Reinforces the separation between decision-makers and litigants
- Prevents quasi-judicial bodies from becoming interested parties
- Upholds the principle that adjudicators must remain neutral, even after their decisions are overturned
- Clarifies that statutory bodies cannot litigate merely to defend their authority
The judgment strengthens public confidence in quasi-judicial institutions by ensuring they do not act as adversarial parties in litigation.
Conclusion
The Kerala High Court’s decision serves as a clear reminder that quasi-judicial authorities are arbiters, not stakeholders. Once their decision is subjected to judicial review, they must accept the outcome with institutional discipline rather than pursue appeals to vindicate their authority.
By holding that the Admission Supervisory Committee lacked locus standi to file a writ appeal, the Court has reaffirmed foundational principles of fair adjudication, neutrality, and rule of law—principles that lie at the heart of India’s constitutional framework.
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