The rule is a hard outer limit: a three-year MDS course must be finished within six years of admission, no matter what. The student here, admitted in 2018, cleared his first-year paper only on the sixth attempt in 2021, missed later exams, and saw his attendance fall to single digits; by the time he asked to continue, the six-year window had all but closed. The Andhra Pradesh High Court held that even taking his case at its highest, he could not possibly complete the course within six years, and that his attendance record was deficient besides. There was, the Court held, no ground to interfere, and the petition was dismissed.
Amaravati: The Andhra Pradesh High Court has dismissed a writ petition by a Master of Dental Surgery (MDS) student challenging his university’s decision to treat him as ineligible to continue the course, holding that under the Dental Council of India’s MDS Course Regulations, 2017, the course must be completed within a maximum of six years from the date of admission, a period the petitioner could not meet [Dr. U. Anudeep v. Dr. N.T.R. University of Health Sciences and Others].
A Division Bench of Chief Justice Lisa Gill and Justice Challa Gunaranjan dismissed the petition.
What the case was about
The petitioner joined the three-year MDS course in May 2018. He could not clear his first-year Basic Sciences paper, which he passed only in 2021, after several attempts, and, because of that backlog, could not appear for the third-year examinations. His attendance, high in the first two years, fell to 39% in 2020-21 and to 4% in 2022-23, and he did not attend classes thereafter. Citing an ailment, he sought to continue the course, and the dispute turned on when he had first applied: he contended that a demand draft he had drawn in March 2023 should count as his request, while the university and college maintained that no application for readmission was received until June 2024, by which time double the duration of the course had already elapsed. The university rejected his request, and he moved the High Court.
The six-year outer limit
The Court turned to Regulation 11(1) of the DCI’s MDS Course Regulations, 2017, which fixes the period of training at three years but provides that the time for passing out of the MDS course shall be a maximum of six years from the date of admission. On a plain reading, the Court held, the course has to be completed within six years of admission, and, for this petitioner, doing so was an impossibility.
The Court found the timing argument did not save him. Even if the demand draft of March 2023 were treated as his request, which, the Court held, was in effect not possible, since it was not accompanied by any formal request letter, he could not, by any stretch of imagination, complete the course within six years of his admission in May 2018. His eligibility on the score of attendance was, the Court added, also clearly deficient. Noting that the petitioner’s counsel was unable to point to any ground calling for interference in the exercise of writ jurisdiction, the Court dismissed the petition.
Why it matters
For students in professional courses governed by a statutory regulator, the case is a reminder that a maximum-duration rule is a hard limit, not a flexible guideline. Medical and dental education regulations commonly cap the total time within which a course must be completed, here, six years for a three-year MDS course, and once that outer limit is reached, or cannot in any event be met, a student loses the entitlement to continue, however sympathetic the reasons for the delay. The rule exists to ensure that those who ultimately qualify have trained within a defined, contemporaneous period, and courts have been reluctant to relax it, particularly as regulators have pressed for strict compliance.
The decision also illustrates the limits of what a writ court will do in such matters. The petitioner’s difficulty was not merely procedural, a dispute over when he applied, but substantive: on the arithmetic of the regulation, he could not finish the course within six years on any version of the facts, and his attendance shortfall compounded the position. Where the bar to relief is the regulation itself, and not some remediable irregularity by the authorities, there is little room for a court to intervene under Article 226; a mandamus cannot direct an authority to do what the governing rules forbid.
The practical lesson for students is to act within time and in the prescribed form. A demand draft, without an accompanying request, was held not to amount to an application, and even a timely application would not have overcome the six-year ceiling. Genuine hardship, including illness, may explain a delay, but it does not, by itself, extend a statutory outer limit; a student facing such difficulty is better served by seeking the appropriate leave or break-of-study permission early, and in the manner the regulations require, than by relying on it after the maximum period has run.
Case Title: Dr. U. Anudeep v. Dr. N.T.R. University of Health Sciences and Others [Writ Petition No. 13043 of 2025]
Bench: Chief Justice Lisa Gill and Justice Challa Gunaranjan, High Court of Andhra Pradesh at Amaravati
Date of Judgment: July 9, 2026
Appearances: Advocate Chukka Kranthi Kiran for the petitioner; Standing Counsel Tata Venkata Sridevi for the University and Advocate C.V.R. Rudra Prasad for the College.
Status: Writ petition dismissed. MDS course held to be subject to a maximum six-year completion period under DCI Regulation 11(1), which the petitioner could not meet; attendance also found deficient.