1. It is respectfully submitted that the action of the Respondent, namely the National Medical Commission (NMC), in issuing notices in the year 2026 requiring Foreign Medical Graduates to repeat parts of their medical education abroad on the ground that certain classes were conducted online during the COVID-19 pandemic is arbitrary, unreasonable and legally unsustainable.

2. The Petitioners submit that during the global outbreak of the COVID-19 pandemic, educational institutions across the world, including medical universities, were compelled to temporarily conduct certain academic activities through online mode due to government restrictions and lockdown measures. However, after the restrictions were lifted, the Petitioners duly returned to their respective universities and completed all pending coursework, clinical postings, and practical training through physical attendance before being awarded their medical degrees.

3. It is further submitted that the concerned foreign universities issued official certificates/compensation letters confirming that the Petitioners had completed all academic and clinical requirements in accordance with the prescribed curriculum. On the basis of such qualifications, the Petitioners appeared in and successfully cleared the Foreign Medical Graduate Examination (FMGE) conducted in India in the year 2021 and thereafter joined government hospitals through competitive examinations or commenced medical practice in private hospitals.

4. The Petitioners submit that if the Respondent authority had any objection regarding the temporary online mode of education during the pandemic period, such clarification or restriction ought to have been notified at the relevant time, i.e., in or around the year 2022 when the Petitioners cleared the FMGE examination. Had such communication been issued earlier, students who were still pursuing their studies in foreign universities could have informed their institutions and appropriate corrective measures could have been taken.

5. Issuing such a notice in the year 2026, long after the Petitioners have completed their medical degrees, cleared the FMGE examination, and in many cases started professional practice, is wholly unreasonable and impractical. The requirement that the Petitioners must now return to foreign universities to repeat portions of their education is financially burdensome, practically impossible, and contrary to principles of fairness and legitimate expectation.

6. Furthermore, the impugned action effectively gives retrospective effect to a regulatory requirement after the Petitioners have already fulfilled all conditions prevailing at the relevant time, including passing the FMGE examination. Such retrospective application of regulatory conditions is impermissible in law and causes grave prejudice to the Petitioners.

7. It is also pertinent to note that the COVID-19 pandemic affected educational systems globally, including medical colleges in India where certain academic activities were also conducted online. Singling out only Foreign Medical Graduates for adverse treatment, despite their successful clearance of the FMGE examination, amounts to discrimination and violates the principles of equality.

8. In view of the above, the Petitioners respectfully submit that the impugned notice issued by the National Medical Commission in 2026, seeking to invalidate or question medical degrees already recognized for the purpose of the Foreign Medical Graduate Examination, is arbitrary, unreasonable and liable to be set aside.