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The Delhi High Court has upheld the National Medical Commission’s (NMC) decision to bar Indian students who completed their medical education across multiple foreign institutions from appearing in the Foreign Medical Graduate Examination (FMGE), observing that such qualifications could compromise the quality of medical professionals entering the country’s healthcare system.
Dismissing the students’ plea, a Bench of Chief Justice Devendra Kumar Upadhyaya and Justice Tejas Karia held that medical education completed in a fragmented manner across two or three different foreign institutions could not automatically be treated as an eligible primary medical qualification.
The September 3 judgment upheld the decision of the authorities, including the National Board of Examinations in Medical Sciences (NBEMS) Examination Ethics Committee, which had declared the petitioners ineligible for the FMGE through a communication issued on May 14, 2025.
Court flags public interest concerns
Making significant observations on the standards expected from doctors seeking to practise in India, the court said that recognising a medical qualification based on fragmented studies at different foreign medical colleges would not be in the public interest.
The court observed that such an approach could result in a compromise in the quality of medical professionals in the country.
The case was filed by Indian students who had pursued medical education at foreign institutions and later sought to appear for the FMGE, the mandatory screening examination for Indian citizens and Overseas Citizens of India holding foreign medical qualifications who wish to register and practise allopathic medicine in India.
The petitioners had initially studied at Micronesia Medical College before moving to other foreign institutions, including Belize Medical University. They argued that their movement between institutions was caused by unavoidable circumstances, including the Covid-19 pandemic, civil unrest, the Russia-Ukraine war, and personal reasons.
They eventually sought to rely on medical qualifications obtained from foreign institutions while applying for the FMGE.
Qualifications from different institutions triggered scrutiny
The dispute arose when authorities found that the students had submitted qualifications from two different institutions covering the same period of study.
The students were initially not allowed to appear for the June 2023 FMGE after the Indian Embassy did not attest to their qualification from Micronesia Medical College. They subsequently relied on a qualification from Belize Medical University while applying for the December 2023 examination.
Upon scrutiny of their documents, however, the authorities found inconsistencies arising from qualifications issued by different institutions for overlapping periods. The students were subsequently declared ineligible, a decision later upheld by the NBEMS Examination Ethics Committee.
The students challenged the decision before the Delhi High Court, arguing that the Indian Medical Council Act, 1956, did not specifically require foreign medical qualifications to be attested by the Indian Embassy or apostilled by the relevant authority in the country where the degree was issued.
They also argued that Belize Medical University had recognised credits earned at Micronesia Medical College under an arrangement between the institutions and had validated their medical qualification.
Embassy attestation necessary for verification
The NMC, however, defended the document-verification requirements, arguing that embassy authentication or apostille was necessary to establish the genuineness of foreign medical qualifications.
The commission also raised concerns about the infrastructure and academic facilities at Micronesia Medical College, arguing that such cases demonstrated why Indian authorities needed to verify the institutions and qualifications of students seeking to enter the country’s medical profession.
The High Court agreed that scrutiny of qualification documents served an important purpose. It noted that verification could help examination authorities prevent candidates relying on fake or false medical degrees from appearing for the FMGE.
The court, therefore, found no reason to interfere with the NMC’s decision.
What the ruling means for foreign medical graduates
The ruling has wider implications for Indian students pursuing medicine abroad, particularly those who transfer between institutions during their course.
The judgment makes it clear that possessing a foreign medical degree alone may not guarantee eligibility for the FMGE. The qualification must also meet prescribed regulatory and verification requirements.
By backing strict scrutiny of fragmented medical education and foreign qualifications, the Delhi High Court has placed public interest and patient safety at the centre of the regulatory process for doctors seeking to practise medicine in India.
