Madhya Pradesh, January 15, 2026: The Madhya Pradesh High Court has clarified that in-service doctors in the state are not required to execute a rural service bond after completion of a medical postgraduate course.
A division bench comprising Justice Vivek Rusia and Justice Pradeep Mittal dismissed a petition filed by a doctor seeking release from the rural service bond and return of her original certificates.
The petitioner completed her PG Diploma in Anesthesia in March 2017 and was subsequently issued a certificate by the MP Medical Science University, Jabalpur. She registered with the Medical Council in July 2017.
She sought release from the rural service bond before the Director of Medical Education, Bhopal. The petitioner submitted before the High Court bench that no posting order was issued to her within three months of the declaration of her PG diploma results, and therefore she should be exempted from the bond requirements as per the rules.
She argued that under the pre-2014 PG rules, if a rural appointment order is not issued within three months, the bond automatically becomes void. Pointing to the fact that no posting order was assigned to her within the stipulated time period, she argued that the bond should be void, pointing to the Health Service Commissioner.
On the other hand, the state government submitted that the petitioner's original certificates had already been returned in compliance with an interim order issued in August 2017. Further, the state government also submitted that an NOC issued to the petitioner clearly stipulated the requirement of performing one year compulsory rural service after completing the PG course.
It was also alleged that before being granted permission to pursue further studies, she was on unapproved leave which was later deemed as "dies non." According to the MP state government, she was appointed as a Medical Officer in Ratlam in December 2016 and was already in government service during the time of her PG diploma.
Competent authority may declare the unauthorized leave as dies non, which may cause break in service and therefore loss in pensions, etc.
The High Court bench noted that an NOC issued by MG Medical College, Indore, required the petitioner to complete one year of rural service before returning the original certificates. More significantly, the court found that the petitioner had concealed the crucial fact that she was already employed as a Medical Officer in Ratlam at the time of filing her petition.
The court interpreted Rule 11 of the MP Autonomous Medical and Dental Post Graduate Courses/Diploma Admission Rules, 2017, observing that this rule applies to selected candidates but not to in-service doctors already employed in government service.
The bench observed that since the petitioner was already employed as a Medical Officer in the Health Service Department and enrolled in the PG course while in service. She was not required to submit a separate bond for rural service. However, the court clarified that in such cases, the doctor must return to their parent service after completion of the course.
The court held that the petitioner had approached the court while concealing material facts, which did not satisfy the principle of "clean hands" required in equity jurisprudence. Based on this finding, the plea was dismissed.
The court stated that if the petitioner wished to rejoin the Health Department as a Medical Officer, she must work in rural or remote areas as per the terms of the bond.
(Rh/VK)