New Delhi: The Delhi High Court has declined to grant relief to a government doctor who challenged the denial of a No Objection Certificate (NOC) and study leave for a postgraduate medical course, upholding the hospital’s decision to follow seniority-based sponsorship when only one sponsored seat was available.
Justice Avneesh Jhingan ruled that the decision taken by the hospital authorities was neither arbitrary nor unreasonable, especially in the absence of any prescribed tie-breaking mechanism under the applicable rules.
The case arose after the petitioner, a government doctor, was denied sponsorship for a PG course in Nuclear Medicine at the Postgraduate Institute of Medical Education and Research (PGIMER), Chandigarh, despite qualifying for the seat.
The denial was communicated through an Office Memorandum dated 19 December 2025, which refused the grant of study leave and NOC on the ground that the maximum permissible number of sponsored doctors from the hospital had already been reached.
The High Court observed that when two eligible candidates compete for a single sponsored seat and the Standard Operating Procedure (SOP) does not specify a selection method, seniority is a valid and relevant criterion.
The court relied heavily on the Office Memorandum dated 02 November 2012, which governs study leave and sponsorship for government doctors. Under Clause 28, the number of officers who may be sponsored at any time depends on the sanctioned strength of the institution, not merely the employer department.
In this case, the hospital was permitted to sponsor only three doctors simultaneously. At the time of consideration, two doctors were already on sponsored study leave, leaving only one available slot, which was granted to a senior officer.
The court also noted Clause 24 of the same OM, which states that no substitute is provided for a doctor on study leave, and that the officer remains on the hospital’s strength and must rejoin after completing the course.
Rejecting the petitioner’s argument, the High Court clarified that permission to appear for the entrance examination does not create a vested right to sponsorship, study leave, or issuance of an NOC.
The court emphasized that eligibility to sit for the exam and entitlement to institutional sponsorship are distinct stages, governed by separate considerations.
The petitioner joined the Directorate General of Health Services, Government of NCT of Delhi on 18 September 2020 and was transferred to Guru Teg Bahadur Hospital in April 2022.
In September 2025, the All India Institute of Medical Sciences (AIIMS) invited applications for sponsored PG medical courses. The petitioner applied on 1 October 2025 and received permission to appear for the entrance examination on 30 October 2025.
He secured a PG seat at PGIMER on 15 November 2025, but was later denied sponsorship due to the seniority-based allocation policy.
The court also noted that in 2023, GTB Hospital had followed the same seniority principle when multiple doctors qualified for PG courses, indicating consistent administrative practice.
Finding no legal infirmity in the decision-making process, the Delhi High Court dismissed the writ petition and all pending applications, concluding that the hospital acted within the framework of existing rules and policies.
(Rh/ARC)