Two High Courts in 2026 have interpreted Rule 3(3) as not expressly confining a qualified radiologist to clinics in only one district. But the decisions do not establish unrestricted multi-district registration, and they do not displace clinic registration, declared consulting hours, employer/service conditions, record-keeping or other PCPNDT obligations.
What Does Rule 3(3) of the PCPNDT Rules Say?
Rule 3(3) of the PCPNDT Rules limits the number of clinics or centres with which a qualified medical practitioner may be registered within a district. The controversy is whether those words also create a territorial prohibition against the practitioner being associated with a clinic in another district.
The operative restriction refers to a maximum of two clinics/centres “within a district.”
Can a Radiologist Be Registered at Ultrasound Clinics in Two Different Districts?
Jagabandhu Barik v. State of Odisha & Ors.
Orissa High Court · W.P.(C) No. 14988 of 2026
The Bargarh authority refused permission by relying on Rule 3(3). The High Court held that the authority had misinterpreted the Rule. It found no express prohibition in the Act or Rules against a qualified radiologist conducting ultrasonography at clinics situated in two different districts.
Dr Shyam Bihari v. State of Haryana
Punjab & Haryana High Court · CRR-3912-2018 (O&M)
The prosecution context was different, but the Court separately examined Rule 3(3). It held that the restriction on registration in a maximum of two diagnostic centres is expressly confined to centres “within a district” and found no statutory bar merely because the centres were located in two different districts.
Are these judgments binding throughout India?
No blanket nationwide proposition should be stated from these two decisions alone. A High Court judgment operates within the constitutional doctrine of precedent and is binding on authorities and subordinate courts within its territorial jurisdiction, subject to higher or larger-bench authority. A decision of another High Court may be persuasive elsewhere. The page should therefore describe these as two supportive 2026 High Court interpretations, not as a nationally settled rule.
What Do These Judgments Not Mean?
The decisions interpret one specific territorial issue. They do not dismantle the PCPNDT compliance framework.
Exactly what is established—and what is not?
| Question | Careful legal position |
|---|---|
| Does Rule 3(3) use the words “within a district”? | Yes. That wording is central to the present interpretation issue. |
| Did the Orissa High Court find an express cross-district bar in Rule 3(3)? | No. The Court rejected that interpretation on the facts before it. |
| Do the decisions abolish the two-centre rule? | No such broad proposition should be stated. |
| Do they permit unlimited centres across India? | Not established by Jagabandhu Barik. The broader question requires caution. |
| Do clinic registration and consulting-hour requirements continue? | Yes. These remain independent compliance questions. |
| Can employer/service rules still matter? | Yes. An NOC/service-rule issue is separate from the textual interpretation of Rule 3(3). |
Why Has PCPNDT Rule 3(3) Been Litigated Since 2012?
Rule 3(3) has been the subject of litigation since soon after its introduction. Earlier proceedings included interim challenges before the Bombay High Court, Delhi High Court, Madhya Pradesh High Court and Punjab & Haryana High Court.
Regulatory Intent vs the Words Actually Enacted
Prevent misuse, enable supervision and discourage proxy or uncontrolled registrations.
The courts have asked whether a wider cross-district prohibition can be read into language that does not expressly contain it.
What Is the Current Legal Position on Cross-District Radiologist Registration?
That proposition should still be applied cautiously. Qualification, clinic registration, practitioner registration/linkage, consulting hours, service conditions, employer permissions and the complete PCPNDT compliance architecture remain independently relevant.
What remains legally unsettled?
Why declared consulting hours matter medico-legally
Cross-district registration is only one question. If declared consulting hours overlap or records place the same practitioner at two centres at the same time, the more serious issue may become factual traceability: who actually performed the scan, whether records accurately reflect presence, whether Form F and attendance documentation correspond, and whether proxy operation is suspected. Thus, territorial permissibility does not eliminate documentary or evidentiary risk.
Document trail that may become important
These documents are listed as potentially relevant evidentiary material; the exact statutory requirement and relevance must be assessed on the facts of the particular case.
Practical compliance points
- Confirm the practitioner's qualification and eligibility under the current statutory framework.
- Ensure the ultrasound/genetic clinic or imaging centre has valid PCPNDT registration.
- Ensure the practitioner is appropriately reflected or registered for the concerned centre.
- Specify and comply with declared consulting hours.
- Check employer NOC and applicable government/private service conditions.
- Maintain Form F, records, declarations, machine documentation and other statutory requirements.
- Do not treat these judgments as blanket permission for unlimited multi-district practice.
Why Appropriate Authorities May Still Scrutinise Cross-District Arrangements
Legitimate regulatory concerns may include physical feasibility, overlapping consulting hours, proxy-use risk, actual operator identity, traceability of examinations and integrity of statutory records. The legal question is not whether those concerns are important; it is whether a particular restriction imposed by an authority has support in the Act or Rules and whether enforcement follows the statutory framework.
LegalMedico takeaway
The significance of the 2026 decisions is not that PCPNDT regulation has been relaxed. The significance lies in the limits of administrative interpretation. A regulatory objective may explain a provision, but it cannot automatically supply words that the enacted Rule does not contain.
For radiologists, diagnostic centres and PCPNDT authorities, the safer reading is therefore nuanced: the two-centre rule and the territorial question must be distinguished from the rest of the compliance framework.
- Jagabandhu Barik v. State of Odisha & Ors., W.P.(C) No.14988 of 2026, Orissa High Court, judgment dated 6 August 2026.
- Dr Shyam Bihari v. State of Haryana, CRR-3912-2018 (O&M), Punjab & Haryana High Court, judgment dated 3 July 2026.
- G.S.R. 418(E), dated 4 June 2012, introducing Rule 3(3), and contemporaneous PCPNDT regulatory material.
- Earlier interim proceedings concerning Rule 3(3), including the Delhi High Court IRIA proceedings, should be read in their precise procedural context before drawing any current nationwide conclusion.