In Brief
V.N. Public Health and Educational Trust sought Essentiality Certificate and Consent of Affiliation to establish a medical college in Kerala. The Trust argued these were ministerial acts that could not be denied once granted. The Supreme Court held that issuance of Essentiality Certificates and Consent of Affiliation involve substantive quasi-judicial evaluation of infrastructure, faculty, and clinical material compliance with prescribed norms—not ministerial functions. Although once-issued certificates ordinarily cannot be withdrawn, the State may refuse renewal if the underlying justification has disappeared through the applicant's prolonged failure to meet norms despite opportunities. Finding significant deficiencies in the Trust's facilities after 17 years of unsuccessful attempts, the Court dismissed the appeals and left open the possibility of fresh applications for future academic years after remedying deficiencies."
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