W.P.(C) No.15925/2019 (M) - Principal, Educare Institute of Dental Sciences v. Kerala University of Health Sciences & Ors.

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE SMT. JUSTICE P.V.ASHA** **WEDNESDAY, THE 07TH DAY OF AUGUST 2019 / 16TH SRAVANA, 1941** ## **WP(C).No.15925 OF 2019(M)** ## **PETITIONER/S:** **THE PRINCIPAL, EDUCARE INSTITUTE OF DENTAL SCIENCES, KILIYAMANNIL CAMPUS, CHATTIPARAMBA,MALAPPURAM-676504.** **BY ADVS. SRI.KURIAN GEORGE KANNANTHANAM (SR.) SRI.P.M.SANEER SRI.TONY GEORGE KANNANTHANAM** ## **RESPONDENT/S:** - **1 KERALA UNIVERSITY OF HEALTH SCIENCES, REPRESENTED BY ITS REGISTRAR,MEDICAL COLLEGE.P.O,TRICHUR-680596.** - **2 THE DENTAL COUNCIL OF INDIA, REPRESENTED BY ITS SECRETARY,KOTLA ROAD, NEW DELHI-110011.** - **3 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF HEALTH AND FAMILY WELFARE,(DENTAL EDUCATION SECTION),NIRMAN BHAVAN,NEW DELHI-110011.** **R1 BY SRI.P.SREEKUMAR,SC,KERALA UTY.HEALTH AND ALLIED SCIENCE R2 BY SRI.PRAKASH M.P., SC, DENTAL COUNCIL OF INDIA R3 BY ADV. SHRI.P.VIJAYAKUMAR, ASG OF INDIA** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 17.07.2019, THE COURT ON 07.08.2019 DELIVERED THE FOLLOWING:** ## **P.V.ASHA, J. ---------------------------W.P.(C) No.15925 of 2019 ---------------------------Dated this the 07[th] day of August, 2019** ## **JUDGMENT** The Principal of Educare Institute of Dental Sciences, which is a self financing college has filed this Writ Petition aggrieved by Ext.P8 order of the 1[st] respondent University by which the request for consent of affiliation to start Post Graduate courses is rejected. 2. It is stated that the petitioner college is established by a religious minority community and based on its application for NOC to start PG programmes Government issued Ext.P1 NOC on 24.05.2011 for starting 8 PG programmes as mentioned therein. It is stated that petitioner had submitted applications before Central Government in 2014 for permission to start PG Dental programmes in the year 2015-16. But it was returned as per Ext.P4 letter on the ground that essentiality ## W.P.(C) No.15925/19 **==> picture [12 x 8] intentionally omitted <==** certificate for each programme and consent of University affiliation for the same were not produced and that application was incomplete. Whileso petitioner received Ext.P2 essentiality certificate on 22.03.2016, from Government for starting PG Dental Courses in specialties of Periodontics and Conservative Dentistry with 3 seats from the academic year 2016-17 onwards, fixing certain conditions. In the year 2016, the Dental Council of India returned its application as per Ext.P5 letter of the Dental Council of India for want of consent of affiliation from the University. Petitioner thereafter submitted Ext.P6 series of applications on 28.12.2018 before the 1[st] respondent University for starting MDS course in Conservative Dentistry Department, Periodontics Department, Orthodontics Department and in Pedodontics and Preventive Dentistry Department. 3. Thereafter petitioner submitted Exts.P7, P7(a) and P7(b) applications on 18.03.2019 before the Central Government remitting the required fee of W.P.(C) No.15925/19 **==> picture [12 x 8] intentionally omitted <==** Rs.3,00,000/-, for starting MDS programmes in the specialty of Orthodontics and Dentofacial Orthopaedics, Conservative and Endodontics and in Periodontology stating that the consent of affiliation from the University would be forwarded as and when the same is obtained. Whileso the University as per Ext.P8 letter dated 09.04.2019 rejected the applications-Ext.P6 series, stating that it had not invited applications for starting new colleges or courses. Ext.P8 is under challenge in this Writ Petition. **==> picture [397 x 11] intentionally omitted <==** (Establishment of New Dental Colleges, Opening of New or Higher Courses of Study or Training and Increase in Admission Capacity in Dental Colleges) Regulations 2006 ('DCI Regulations' for short), applications are to be submitted between 15[th] March and 7[th] April. 5. According to the petitioner, refusal on the part of the University to invite application for permission to start new courses is violative of its fundamental rights guaranteed under Article 19(1)(g) W.P.(C) No.15925/19 **==> picture [12 x 8] intentionally omitted <==** and 30(1) of the Constitution. It is also its contention that statute 31 of chapter 21 of the University First Statute mandates the University to call for applications and also to prescribe the date for submitting application for permission. Petitioner is therefore seeking a direction to reconsider its applications on merits and for a direction to the University to act in accordance with Statute 31 so as to enable the petitioner to submit application as provided therein. There is a further prayer also for a direction to respondents 2 and 3 not to reject its application for new courses. 6. During the pendency of the Writ Petition the petitioner received Ext.P9 letter dated 11.06.2019 from the Dental Council of India in which it is stated that the Central Government has forwarded the application of the petitioner for starting MDS courses and it was considered by the Executive Committee in its meeting held in 6/2019 and that accepting the suggestions of the sub committee, it was decided to ask the college to ## W.P.(C) No.15925/19 :6: rectify the deficiencies and to furnish the compliance report to the Dental Council of India. The 1[st] deficiency noted is non-production of consent of affiliation from the University for MDS courses. 3 other defects are also pointed out. The learned Senior Counsel for the petitioner submitted that all the deficiencies except the consent for affiliation from the University are rectified. 7. In the statement filed by the ASGI of India on behalf of the 3[rd] respondent, the procedure for submitting application before central Government and procedure after receipt of application under Section 10A of Dentists Act 1948 read with the Regulations 2006 made under section 10A read with section 20 of the Act, are explained. It is further stated that petitioner submitted application dated 18.3.2019 for starting MDS courses in three specialties for the academic year 2020-21. The applications were sent to the 2[nd] respondent as per letter dated 25.04.2019. But petitioner did not forward the affiliation letter from ## W.P.(C) No.15925/19 **==> picture [12 x 8] intentionally omitted <==** the University. Relying on the judgment dated 11.01.2019 in WP(C) No.10767/2018 of the High Court of Delhi it is stated that as the application submitted by the petitioner was not accompanied by the requisite consent of affiliation by the University and therefore in the absence of a complete application as on the last date fixed for receipt of application, the application submitted by the petitioner cannot be considered. 8. The University has filed a statement. It is stated that the University has initiated steps to have a perspective plan in place and after in-depth analysis of the existing condition of the medical education in the state the perspective plan has been drafted and it would be finalized and notified shortly. In the above circumstances the University decided not to invite application for affiliation of new course or enhancement of the seats in different courses as was done in previous years. Therefore no notification was issued inviting applications by the University. It is the contention of the University that unless it invites W.P.(C) No.15925/19 **==> picture [12 x 8] intentionally omitted <==** applications petitioner cannot have any right to insist that University has to receive its application or process the same. In paragraph 3 it is stated as follows: _3. The contentions raised in the writ petition to suggest that a legal duty is cast on the university to invite applications for affiliation every year is incorrect. The university is keeping in mind the objectives of the university and the need to safe guard the standard of the courses. Mushrooming of the institutions in the state would lead to the deterioration of the standards in the medical education. The provisions in the KUHS act contemplate the affiliation of the courses depending on the perspective plan which is to be put in place by the university. In the initial years of the incorporation of the university the perspective plan was not available and the university was considering the application for affiliation based on the individual applications_ . 9. It is also stated that the last date fixed for submitting application for the academic year 2020-21 was 7.4.2019 and that an application submitted without all the requisite documents including consent of affiliation would be treated as incomplete and therefore petitioner cannot have any right to seek for a direction to the University to issue consent for affiliation. W.P.(C) No.15925/19 :9: 10. The learned Senior Counsel appearing for the petitioner relied on the judgment of this Court in _**St.Joseph's Hosptial Trust vs. Kerala University of Health Sciences: 2012 (4) KLT 444**_ and argued that the fundamental right of the petitioner is being violated at the instance of the University. Relying on the judgment in W.A.No.1485/2019 it was argued that the contention of the University that the petitioner has to await the notification by the University inviting applications for consent will no longer hold good as the Division Bench has already directed to accept applications from the colleges and consider it on merits. It was noticed that the University has all these years processed the applications even in the absence of any notification. 11. On the other hand the learned Standing Counsel relying on the judgment of the apex court in _**DM Wayanad Institute of Medical Sciences vs. Union of India and another : (2016) 2 SCC 315**_ argued that the petitioner does not have any fundamental right under Article 19 W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** (1) (g) for affiliation or consent from the University. The judgment dated 29.02.2018 in the _**Jawaharlal Nehru**_ _**Technological University Registrar vs. Sangam Laxmi Bai**_ _**Vidyapeet & Ors in SLP No.9718/2018**_ was also relied on in support of the contention that the University has every right to look into the local conditions, the socio economic problems arising out of the mushrooming of the institutions without any restrictions. It was pointed out that the dictum laid down in the judgment in _**Jaya Gokul Education Trust v. Commissioner & Secretary to Government of Higher Education Department, Thiruvananthapuram, Kerala : 2000(2) KLT 267:(2000) 5 SCC 231,**_ relied on by the learned senior counsel has been watered down and it is no longer a good law. It is pointed out that several of the colleges are being shut down and it is becoming difficult to accommodate the students of such colleges in other institutions and to protect the interest of the students who are in the midst of the courses and that it has become necessary to take steps to stop the mushrooming of colleges which results in very serious socio economic problems. W.P.(C) No.15925/19 **==> picture [17 x 8] intentionally omitted <==** According to the learned Standing Counsel the permission contemplated for additional courses as in this case and regarding the applications for affiliation considered by the Division Bench are different and therefore it cannot be compelled to receive or accept the applications. 12. On consideration of the contentions on either side, it is necessary to have a look at Regulation 13 of Ext.P3 Regulations. Clause 4 provides that the proposal or scheme for establishing a new dental college or for opening a new or higher course of study or training or increasing in-take capacity in a dental college shall be made to central government in Form 1, 2 and 3, for obtaining its permission under the Act. Clause 2 thereof provides that the scheme or proposal shall be made within the time schedule provided in the schedule. Regulation 13 provides for the qualifying criteria which reads as follows: _13. Qualifying Criteria.-_ _A dental college shall qualify for starting a new or higher course of study or training in dental_ W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** _subjects, the following conditions are fulfilled:-_ _(a) the dental qualification granted to the students of the dental college is recognised for running BDS course and conforms to the norms laid down by it;_ _(b) deleted vide (12[th] amendment) notification dated 11.10.2017._ c) _letter of University’s permission, valid for the entire duration of the course, for starting such course or training at the dental college has been obtained by it from the University to which it is affiliated;_ _(d) the dental college has the full complement of staff, equipments and other infrastructure facilities prescribed for under-graduate training programme and also fulfils additional requirements in respect of funds or allocation of finances, staff and other infrastructure facilities as per the norms prescribed by the Council and approved by the Central Government under Section 20 of the Act in the M.D.S. Regulations, I9S3 and P.G. Diploma Regulations, 1983, as amended from time to time._ _(e) selection of candidates for post-graduate degree and post-graduate diploma courses will be made strictly on the basis of academic merit._ 13. Therefore a letter of permission from the University is mandatory for starting a new course, as per the Regulations framed by the Dental Council itself. Regulation 14 provides for submission of application in Form 2. Regulation 14(2) provides that incomplete applications would be returned by the Central Government to the dental college along with W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** enclosures and application fee. Regulation 14(3) provides that the application submitted under the regulation, if found complete in all respects, will be forwarded by the Central Government to the Council within 30 days of the receipt of such application for evaluation and recommendations. Regulation 17 (1) provides that the Central Government may after considering the scheme submitted in form 2 under regulation 14 and the recommendations of the Council thereon, with reference to the Act, issue a letter of intent to grant permission subject to such conditions or modifications as it may consider necessary. It also provides that formal permission would be granted by the Central government after the conditions stipulated and modifications suggested are accepted by the dental college. Therefore the Central Government is supposed to forward only those applications which are complete in all respects. For an application to be complete, the college should have produced all the documents prescribed in clause 13 before the last date fixed for the same, as provided in Clause 4(2). An application in W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** form 2 requires enclosure of certified copy of the letter of affiliation by a recognised University. 14. Chapter VII of the Kerala University of Health Sciences Act, 2010 deals with permission, affiliation and recognition of colleges wherein section 50 deals with affiliation and recognition and section 51 deals with procedure for permission. Section 51 reads as follows: ## _**Procedure for permission.-**_ _1. The University shall prepare a perspective plan for educational development for the location of institutions of higher learning in a manner ensuring equitable distribution of facilities for higher education in Medical and Allied Sciences having due regard, in particular, to the needs of unserved and underdeveloped areas within, the jurisdiction of the University. Such plan shall be prepared by the Academic Council and got approved by the Governing Council and shall be placed before the Senate. It shall be updated every five years. 2. No application for opening a new college or institution of higher learning which is not in conformity with such plan, shall be considered by the University. 3. No students shall be admitted by the college or institution unless the first time affiliation has been granted by the University to the college or institution. 4. The rules and procedure for affiliation of a college to the University shall be as prescribed by the Statutes._ Thus it can be seen that as per sub-section (1) of section 51 the University has to prepare a perspective W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** plan. Sub section 2 prohibits consideration of any application for opening a new college or institution of higher learning which is not in tune with the plan. Sub section 4 provides that the rules and procedure for affiliation of the college to the University shall be as prescribed by the Statutes. Chapter XXI of the Kerala University of Health Sciences First Statutes, 2013 deals with affiliation of colleges. Statute 2 thereof reads as follows: _2. Date of application- Applications for affiliation of a college or for affiliation in additional subjects or affiliation for enhancement of seats or for consent of affiliation shall be addressed to the Registrar, and shall be forwarded to him on or before the date fixed by the University from time to time._ 15. Statute 3 provides for form of application. Statute 4 provides for application for additional affiliation. The format of applications are to be issued by the University from time to time as provided in statute 3. Application for additional affiliation are to be submitted under Statute 4. Clause 2 of statute 8 provides that on receipt of application for affiliation of new college or a new course, the W.P.(C) No.15925/19 :16: University shall consider whether it is in consonance with the perspective plan approved by the governing council or educational development as required under section 51 of the Act. Grant of affiliation is provided under statute 10. Statute 31 provides for additional affiliation which reads as follows: _**31. Additional affiliation.-** When a college desires to institute additional courses of subjects of instruction, including courses of a higher standard, an application for permission to institute additional courses shall be made to the Governing Council in the prescribed manner, and before a prescribed date and every college shall obtain the prior approval of the Governing Council before starting the courses._ Statute 33 which provides for conditions for obtaining permission to provide instruction in Post Graduate courses of study reads as follows: ## _**33. Conditions for obtaining permission to provide instruction in Post Graduate courses of study.-** For_ _the purpose of obtaining permission to provide instruction in Post graduate courses of study, an affiliated college shall satisfy the following conditions, namely;_ _a. that there are adequate financial resources for the continued maintenance and efficient working of the post graduate section or sections of the college;_ _b. that there shall be provided suitable and adequate accommodation for students, staff, library, laboratories, hospital, museums, scientific equipment and ether technical appliances_ W.P.(C) No.15925/19 :17: _which may be necessary for the purpose of providing post graduate instruction and research in respect of which permission is applied for;_ _c. that adequate provision has been or shall be made for a library properly equipped, including internet and computer laboratory facility, for the post graduate courses of study sought to be undertaken by the college;_ _d. that, where post graduate instructions is sought to be imparted in any branch of experimental science; arrangements have been or shall be made in conformity with the regulations for imparting such instruction in a properly equipped laboratory or museum;_ _e. that necessary arrangements have been or shall be made for the conduct of lecturers, tutorials and practical and other means of imparting instruction in the intended post graduate course of study; and_ _f. such other conditions or directions as the Governing Council may from time to time lay down for the maintenance of the standard of post graduate study._ 16. Therefore under clause (f) of Statute 33, the governing council of the University is free to lay down conditions, as it thinks fit, for the maintenance of standards of post-graduate study. As stated by the University it is dutybound to safeguard the standard of the courses and to protect the institutions from deterioration of standards in the medical education. It W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** is also pertinent to note the following observations of the Division Bench of this court made in 2012 in ## _**St.Joseph's college's**_ case (supra). _“47. xxx Undoubtedly, we share the anxiety of the Division Bench that there is a deplorable fall in the standards of education in Engineering Colleges in the State. We would, in this regard, notice that the powers of the University include the power to prescribe conditions for recognition of institutions for conducting research or other programmes of the University and to grant recognition to institutions satisfying the conditions and to withdraw such recognition (S.6 Clause (ix) of the Kerala University of Health Sciences Act, 2010). S.6(xx) deals with the power to monitor and evaluate.xxxxxxx We would think that there are ample powers with the University to deal with the problem of fall in standards which we would expect the University to adopt all possible measures in accordance with law, so that the alarming fall in standards is arrested. Xxx.”_ ## 17. The deplorable conditions are becoming worse as seen from the number of cases coming up before this court seeking intercollege transfer, for closing down the professional colleges- both medical and technical institution and for allocation of students to other colleges in the midst of the courses. ## 18. Consent of affiliation is a pre-condition for consideration of application by the Central Government. The application is liable to be forwarded to the Dental W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** Council of India, only if it is complete in all respects, for which the application should have been accompanied by a consent of affiliation by the University. 19. In the judgment in _**Jayagokul Trust**_ , the question which arose for consideration before the apex court was regarding the requirement in Statute 9(7) of the Kerala University First Statute that the University must ascertain the views of the Government when the AICTE had already given its approval and the question of approval is governed by the central Act. It was held that the State law if at all it sought for approval of the State for establishing technical institutions, would be repugnant to the AICTE Act. The Apex Court also held that the said provision only means that the University must obtain the views of the Government. The application of the said dictum does not arise in this case, as the application itslef is to be submitted along with affiliation letter of the University. In the judgment in _**St.Joseph's Hosptial**_ W.P.(C) No.15925/19 :20: _**Trust**_ the Division Bench of this court was considering cases in which affiliation was denied on the basis of a government circular/consent of affiliation was granted on condition that the college has to obtain NOC from government; it has to produce the agreement executed with government for seat sharing, etc, on the basis of a circular issued by Government. The Division Bench was considering the authority of government to dictate terms to University, as evident from para 4 of the judgment which read as follows. _“we are not called upon to sit in judgment over the exercise of any power by the University. We are essentially called upon to decide upon the authority of the Government to dictate to the University that it need not give affiliation, unless and until certain conditions are satisfied, which include the obtaining of No Objection Certificate from it.”_ 20. Regarding the contention of the petitioner as to violation of fundamental right, the right to establish an institution for imparting medical and technical education will not extend any fundamental right to affiliation or for consent of affiliation, as rightly contented by the learned Standing Counsel, and found in the judgment in _**St.Joseph's College's**_ case. W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** It is also relevant to note the judgment of the apex court in _**Medical Council of India vs. V.N. Public**_ ## _**Health & Educational Trust and others : (2016) 11 SCC**_ _**216**_ wherein it was held as follows: _15.xxxx The Schedule prescribed by the MCI, which had been approved by this Court, is binding on all concerned. MCI cannot transgress it. The High Court could not have gone beyond the same and issued any direction for conducting an inspection for the academic year 2016-17. Therefore, the directions issued by the learned single Judge and the affirmation thereof by the Division Bench are wholly unsustainable._ 21. Therefore the petitioners cannot insist that the University has to grant consent of affiliation to it. From the statement filed by the learned ASGI it is clear that the application was to be submitted in its complete form before the prescribed date or otherwise it is liable to be rejected. In this case there is no such application which is complete. However, the letter dt.03.07.2019 issued by the Dental Council of India, asking the petitioner to produce the University's affiliation for the courses show that the central government has forwarded an incomplete application to the Dental Council, and that the executive committee of W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** the Council had considered such an application submitted by the petitioner in its meeting held on 26.6.2019, contrary to the provisions contained in Ext P3 Regulations as well as contrary to the procedure explained in the Statement filed by te ASGI, relying on the Regulations. 22. Though the learned Senior Counsel for the petitioner argued that the issue arising in this case is covered by the judgment in W.A.No.1485/2019, it is seen that the appellants in those case were seeking directions for affiliation of new colleges. In this case the petitioner is seeking consent of affiliation for starting a higher course. The application for starting the course requires to be accompanied by the consent of affiliation. In the case covered by the Writ Appeal the AICTE had granted approval. Therefore the petitioner cannot treat himself to be in the same position as that of the appellants in those cases, though the application is rejected on the ground that the University has not invited applications. 23. Though the application is rejected on the W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** ground that the University has not invited any application, University has in para.3 of its statement stated the circumstances under which it did not invite applications. In this context it is relevant to note the observations of the Supreme Court in the judgment in _**Jawaharlal Nehru Technological University Registrar's**_ case ( _supra_ ). _“13. The provisions contained in section 20 are wholesome and intend not only to cater to the educational needs of the area but also prevent the mushroom growth of the institutions/courses. In case institutions are permitted to run each and every course that may affect the very standard of education and may ultimately result in substandard education. There is already a paucity of well-qualified teachers in a large number of institutions and the available seats in Pharmacy course in the Hyderabad city are remaining vacant every year in spite of the reduction in a number of seats. It had not been possible to fill up the vacancies due to non-availability of students. Thus, it is apparent that when 30 institutions in Hyderabad city are already running Pharmacy course, the refusal to grant NOC by the University was wholly justified.”_ ## 24. In this case the application as prescribed under clause 4 of Ext.P3 Regulations ought to have been submitted before the Central Government along with all documents before the date prescribed in the schedule, which according to the respondents was in May 2019. In these circumstances, I find that a direction to the W.P.(C) No.15925/19 **==> picture [18 x 8] intentionally omitted <==** respondent University at this stage to consider the application for consent of affiliation is unwarranted. 25. Under Clause 2 of Statute 8 of the University Statute, the University has to consider whether the application is in consonance with the perspective plan. However so far there is no perspective plan. Therefore, in case the University does not publish the perspective plan or does not call for applications by January 2020, the University shall reconsider Ext.P6 series of applications and pass orders on merits, before February 2020. The Writ Petition is disposed of accordingly. ## **Sd/-** **P.V.ASHA** **JUDGE** rkc W.P.(C) No.15925/19 :25: ## **APPENDIX** ## **PETITIONER'S/S EXHIBITS:** **EXHIBIT P1 TRUE COPY OF THE NO OBJECTION CERTIFICATE DATED 25.4.2011 ISSUED BY THE GOVERNMENT.** **EXHIBIT P2 TRUE COPY OF THE ESSENTIALLY CERTIFICATE FOR MDS COURSE DATED 22.3.2016** **EXHIBIT P3 TRUE COPY OF THE NOTIFICATION DATED 12.1.2006 ISSUED BY THE 2ND RESPONDENT. EXHIBIT P4 TRUE COPY OF THE LETTER DATED 6.8.2014 ISSUED BY THE 3RD RESPONDENT.** **EXHIBIT P5 TRUE COPY OF THE ORDER DATED 7.6.2016 ISSUED BY THE 2ND RESPONDENT.** **EXHIBIT P6 TRUE COPY OF THE APPLICATION DATED 28.12.2018 TO THE 1ST RESPONDENT PERMITTED TO START MDS COURSE IN THE CONSERVATIVE DENISTRY DEPARTMENT.** - **EXHIBIT P6 A TRUE COPY OF THE APPLICATION DATED 28.12.2018 TO THE 1ST RESPONDENT PERMITTED TO START MDS COURSE IN THE PERIODONITICS DEPARTMENT.** - **EXHIBIT P6 B TRUE COPY OF THE APPLICATION DATED 28.12.2018 TO THE 1ST RESPONDENT PERMITTED TO START MDS COURSE IN THE ORTHODONTICS DEPARTMENT.** - **EXHIBIT P6 C TRUE COPY OF APPLICATION DATED 28.12.2018 TO THE 1ST RESPONDENT PERMITTED TO START MDS COURSE IN THE PEDODONTICS AND PREVENTIVE DENTRISTRY DEPARTMENT.** ## **EXHIBIT P7** **TRUE COPY OF THE COVERING LETTER DATED 18.3.2019 TO THE 3RD RESPONDENT .SUBMITTED ALONG WITH EXT.P6 APPLICATION.** W.P.(C) No.15925/19 :26: |**EXHIBIT P7**|**A**|**TRUE COPY OF THE COVERING LETTER DATED**|**TRUE COPY OF THE COVERING LETTER DATED**|**TRUE COPY OF THE COVERING LETTER DATED**| |---|---|---|---|---| |||**18.3.2019**<br>**TO**|**THE**|**3RD**| |||**RESPONDENT.SUBMITTED**|**ALONG**|**WITH**| |||**EXT.P6(A)APPLICATION.**||| |**EXHIBIT P7**|**B**|**TRUE COPY OF COVERING **|**LETTER **|**DATED**| |||**18.3.2019**<br>**TO**|**THE**|**3RD**| |||**RESPONDENT.SUBMITTED**|**ALONG**|**WITH**| |||**EXT.P6(B)APPLICATION.**||| |**EXHIBIT P8**||**TRUE COPY OF THE ORDER**|**DATED 9.4.2019**|| |||**ISSUED BY THE 1ST RESPONDENT.**||| EXT.P9: TRUE COPY OF THE COMMUNICATION DT.11.6.19 ISSUED BY THE DENTAL COUNCIL OF INDIA TO THE PETITIONER.