Whether the New P.G.(Amended) Regulations 2012 will serve the expected and the desired goal?
Prof. (Dr.) Ravi M. Nair
I would like to invite your attention to the Homoeopathy (Post Graduate Degree Course) M.D.(Hom.) (Amendment) Regulations 2012 of the CCH published in the Gazette of India on 5th March, which is available in the CCH website. If you go through it, you will get to know ever so many serious flaws, and defects rendering the whole exercise of P.G. course as worthless and purposeless, besides making it practically difficult on the part of the Universities, students, teachers, and the College authorities. This situation, as it appears to me, is not worth enough for the development of Homoeopathy. I have made an attempt to sort out certain deficiencies and flaws in these Regulations, a copy of which is enclosed for your information and appropriate reciprocation. I also enclose a copy of the detailed syllabus of the General Subjects included in the P.G. Regulations of 2001 for your information and response to the effect that whether these subjects need to be included in the New Regulations. It is desirable to have a debate conducted at national level at the earliest and try to bring home the authorities urgency for correcting and revising the Regulations before implementation. Hope you will do what is necessary.
P.G. Regulations in Homoeopathy were first brought into force in November 1989. It was subsequently amended in February 1993, involving only a few corrections in expressions or words. But on 31st October 2001, an amendment was notified bringing in comprehensive changes in the syllabus giving a scientific basis capable of giving a clear objective analogous with the Regulations in the P.G. programmes of other systems of medicine. There were only 3 specialities in the first Regulations of 1989. In the second Regulations of 2001, the number of these specialities was increased to 7.
- P.G. Regulations in Homoeopathy were first brought into force in November 1989. It was subsequently amended in February 1993, involving only a few corrections in expressions or words. But on 31st October 2001, an amendment was notified bringing in comprehensive changes in the syllabus giving a scientific basis capable of giving a clear objective analogous with the Regulations in the P.G. programmes of other systems of medicine. There were only 3 specialities in the first Regulations of 1989. In the second Regulations of 2001, the number of these specialities was increased to 7.
- The P.G. programmes existed prior to 2001 Regulations were only external P.G. programmes conducted in a few colleges under certain Universities. There were only a few colleges which conducted Regular P.G. Programmes as laid down in the 1st Regulations. It was only after the enforcement of the P.G. Regulations of 2001 that several colleges sprang up under more and more Universities. One decade has elapsed since the enforcement of the 2001 Regulations. Even at this juncture, it cannot be said that colleges and the Universities have become fully familiarised and equipped with the various formalities, infrastructures, schemes, teaching aids, programmes, method of training and evaluation / examinations etc. based on the above Regulations. But this smooth process of transition ensuring a sound foundation for the P.G. programmes in Homoeopathy on a systematic basis capable of yielding the desired goal conceived in the above Regulations has been totally jeopardized by the New Regulations of 2012 which smacks of nothing but a regression or roll-back to the stale Regulations of the last century! What it displays is only ignorance or absence of academic sense and sensibility on the part of the protagonists of the new Regulations , let alone their lack of resourcefulness and imaginative prowess embedded in experience in these matters.
- A Post Graduate programme should be derived and designed with the prime intention or objective to impart specialized training on a specific subject. This alone can mould and produce a competent specialist and / or Medical teacher / Researcher in a particular subject. The Regulations of 2001 were so structured as to give due consideration and weight on the above aspect of specialization. But the latest Regulations strikes a great deviation from the above by registering a close similarity and semblance to the out-dated Regulations of 1989.Accordingly, a scholar has to undergo training in two subsidiary subjects along with the speciality subject. It is also stated that these subsidiary subjects have to be studied in depth and content of the syllabi as have been prescribed for their speciality course for all the intent and purpose of examinations. (Please see the last sentence of the clause 4 of the new Regulations.)
- This is more clear from a perusal of the scheme of Examinations stated in clause 5 of the new Regulations. The only meager difference is that there is one more paper in the specialty subject in Part – II examinations. It is a serious point to be pondered over how it will be possible for a student to study all the 3 subjects in the same dimension of depth and content in a course of 3 years duration. This will definitely weaken his concentration and result in relatively lesser understanding and comprehensions of the speciality subject he will be choosing.
- The subjects viz. Organon of Medicine, Materia Medica, Repertory are the basic ones essentially required for the practice of Homoeopathy. Accordingly, they become clinical subjects. The clinical conditions are broadly classified into three viz. Medical, Surgical and Obstetric & Gynaecological. In the practice of Homoeopathy, the knowledge of basic subjects of Homoeopathy has to be applied in an integrated manner in tandem with the above clinical conditions. So when a P.G. curriculum for the above said Homoeopathic subjects is planned, the remaining two Homoeopathic subjects and the clinical subjects dealing with the above said broadly classified conditions should also be incorporated as allied / related subjects. Likewise, when a P.G. programme is chalked out for a clinical subject (viz. Medicine, Surgery, OBG or their sub specialities such as Paediatrics, Psychiatry etc.) the 3 basic subjects of Homoeopathy need to be studied as allied / related ones. But these allied / related subjects are not to be dealt with in detail as separate entity as in the case of U.G. (BHMS) curriculum. If such a separate entity-wise study is further mooted in the P.G. programme, the P.G. course will demean itself to the level of U.G. course. In order to obtain the avowed depth in knowledge and skill in a particular speciality, that subject need to be taken in wholesome after effecting judicious integration with the related allied subjects. Any attempt aimed at a study without integration of the main speciality subject with the related subjects, only a smattering knowledge and skill can be achieved in that speciality.. This is the core defect of the Amended new Regulations of 2012.
- The new Regulations have deleted the general subjects like “Holistic concept of Man in Health and Disease” dealing with the study of basic medical subjects viz. Anatomy, Physiology, Biochemistry & Bio Physics, Psychology, Pathology, Pathophysiology, abnormal Psycology, Concept of Miams etc. from the Regulations of 2001. In all P.G. programmes in medical science, the applied aspects of basic medical subjects is a ‘must’ in the preliminary part of the course. The knowledge and skill of the desired speciality subject should be imbibed on the foundation of the above basic subjects. Even though the above basic subjects are taught in the U.G. level, it is an imperative necessity to study these subjects for the effective practical application of the knowledge in clinical conditions in an integrated manner. Despite the assertion that Homoeopathy holds high “holistic concept in health and disease of a man”, nothing tangible is seen ever undertaken in the curriculum of U.G. course. Unless and until these subjects are taught and studied in an integrated manner, the Homoeopathic perspective will definitely get lost even in the P.G. programme. This is another major flaw seen in the new Regulations of 2012.
- In the New Regulations, the subsidiary subjects prescribed for P.G. course in Homoeopathic Pharmacy are Practice of Medicine and Materia Medica or Homoeopathic Philosophy similar to that of a clinical speciality in Homoeopathy, ignoring the fact that Pharmacy is not at all a clinical subject. This is regarded only as a para medical / para clinical subject every where. As Materia Medica has been separately provided for understanding the medicinal properties in Homoeopathy, what a physician can be expected to derive from the study of subject Pharmacy is only that relating to dispensing the medicines. This has no relevance in clinical practice of a Homoeopath. What a P.G. course in Pharmacy can aim at is only the moulding or making of a teacher in Pharmacy or an expert in the Homoeopathic Pharmaceuticals. In a P.G. course in Pharmacy, the subjects to be taught must be the ones related to Pharmacy alone. Homoeopathic subjects related to Pharmacy can be taught as allied subjects. In the New Regulations, Practice of Medicine has been included as compulsory subsidiary subject, which is against all logics and sane reasoning.
- The colleges will also confront great difficulties and hardships to provide and arrange the adequate infrastructures including staff designed towards efficiently catering to such needs. If the new syllabus is insisted on, a college with two spcialities in P.G. course, for example Psychiatry and Paediatrics or Pharmacy has to provide the entire infrastructures and staff required for the remaining 4 subjects destined to become subsidiary subjects viz. Organon of Medicine, Materia Medica, Practice of Medicine and Repertory to the above specialities programme at one and the same time. Again if a P.G. programme has to be conducted in any one or two subjects viz. Organon of Medicine / Materia Medica / Practice of Medicine / Repertory, additional facilities and staff have to be brought in other three or two subjects also.
- The already existing facilities in the above 4 subjects for the U.G. level will never suffice the required infrastructure and staff demanded by the P.G. course. This factor has been lost sight of while prescribing the staff pattern for manning the P.G. course as stated in clause 7 (b) of the new Regulations.
- As one of the subsidiary subjects happens to be optional to the students, the students in a particular batch in full may be opting one subject against the two subjects. This will render the facilities and faculties reserved for the second subject to lie idle or unused for the whole year simultaneously requiring the management to preserve their existence unnecessarily for no use at all. In a Govt. college such additional staff and infrastructures will not be sanctioned in excess of the Regulations as such action will arouse unnecessary audit objections and irregular commitments on the part of the College authorities.
- There are no. P.G. courses in any other medical faculty insisting the study of any subsidiary subjects (in full required in their speciality subject). Here two subjects are insisted on in Homoeopathy. There can be allied subjects concerned to a speciality subject in a P.G. programmes as stated above.
- The P.G. programme in any clinical speciality in Homoeopathy shall require enough knowledge in the basic subjects of Homoeopathy viz. Organon of Medicine, Materia Medica and Repertory. The new Regulations provide a course only in any of the two basic subjects in Homoeopathy. What is essentially required is the judicious integration of all these three subjects for efficient practice in Homoeopathy. It may thus be seen that the new Regulations are fraught with serious draw backs involving many omissions and commissions which will result in the failure of making and moulding even a competent Physician in Homoeopathy, let alone a competent medical teacher in the speciality discipline.
- These Regulations do not mould a specialist / or a competent teacher in any of the basic subjects of Homoeopathy viz. Organon of Medicine, Materia Medica and Repertory. It is because Practice of Medicine alone has been prescribed as subsidiary subject in their syllabus. The clinical conditions are broadly classified into three, viz. Medical, Surgical and Obstetrical & Gynaecological. Each of the 3 basic Homoeopathic subjects does have its own application in all the 3 clinical conditions stated above. This makes it imperative to have a comprehensive knowledge in the subject concerned. This being the case, in the new Regulations only Medical conditions (study through Practice of Medicine as subsidiary subject) has been prescribed. There is no mention of surgical or OBG conditions.
- Attempts are understood to be on to annex a detailed syllabus of each speciality and subsidiary subjects on the belated realization of the drawbacks of the New Regulations with regard to its implementation on the part of the CCH. It is learnt that this matter is being put to discussion sooner. The proposed detailed syllabus should have to be made part and parcel of the New Regulations if it is to acquire a uniform pattern making it worthy of being implemented in the country. It is in effect an Amendment to the New Regulations even though it appears to be a supplement to it. Any such amendment being thought of within the purview of Rule 20 of the HCC Act 1973 has to be circulated to all State Governments by the CCH for getting their comments in the matter. Only after then, this may be forwarded to the Central Govt. for its sanction.
- Even if it is granted that the proposed amendment will be ready for being published soon, the University will be requiring at least a minimum of 6 months to enforce it after duly amending their Regulations in consistence with the New Regulations. With a view to avoiding the time delay involved in amending the CCH Regulations as pointed out in the previous para, it may be felt expedient to circulate the supplementary syllabus to the University for including them in their new Regulations to implement them in this academic year itself. This will result in more chaotic and confused state of affairs as the Universities will be at liberty to effect their own changes in the Regulations to suit their convenience which may be contrary to the uniformity and homogeneity of the Regulations in the national level, if this act is indulged in supersession without being included in the CCH Regulations.
- Thus whatever hasty action is taken to enforce the New Regulations in the current academic year itself, it will be clear that the entire P.G. programme will become distorted and detrimental to the homogeneity and uniformity resulting in the total inability to achieve the avowed purpose.
- It has been the usual practice with the formulators of syllabi that they used to make it a point to publish the Regulations sufficiently well before the beginning of the academic year by atleast 6 to 7 months ahead. What this action displays is a seasoned wisdom on the part of the CCH to see that enough time is given to the University for amending their Regulations making available sufficient time to finalize their formalities by the different Bodies in the University.
- The P.G. Regulations of 1989 and those of 2001 were published in November of the respective years, giving sufficient time to the Universities at their disposal to satisfactorily complete their formalities before the advent of the subsequent academic year which formally starts on 1st June. But the present Amended Regulations of 2012 were published in March 2012, with no regard being given to this factor, thereby depriving the Universities of their essential convenience to complete their formalities inherent in a process of transition before the beginning of the new academic year.
- What is at stake today is that almost all the Universities which started their courses for the academic year 2012-2013 in June, could not invoke the amended CCH Regulations 2012 (published in March). So what is possible and practical left to be resorted to at this time is that the Universities may be allowed to follow their Regulations in force as on the date of starting their courses in this academic year.
- It is, therefore, requested that the CCH may be appreciative enough to grasp the above factors and to relent themselves to postpone the implementation of the New Regulations to a later period atleast after a spell of one academic year that is in 2013-14. The meantime can be properly utilized for making the New Regulations in conformity with the HCC Act 1973. In anyway a significant factor to be looked into is that the Universities should be given atleast a period of 6 months for preparing themselves to implement every New Regulations.
Prof. (Dr.) Ravi M. Nair
- Former Advisor (Homoeopathy), Dept. of AYUSH, M/o. H&FW, Govt. of India,
- Rtd. – Sr. Principal & Controlling Officer, Homoeopathic Education, Govt. of Kerala
- Former Dean, Faculty of Homoeopathy, University of Kerala.
- Former Chairman, Boards of Studies in Homoeopathy for U.G & P.G., University of Kerala.
- Former Member, Academic Council and Senate, University of Kerala.
- Former Member, Senate, The Tamil Nadu Dr. M.G.R. Medical University, Chennai
- Former Member, Executive Committee, Central Council of Homoeopathy, Govt. of India
- Former Member, Governing Body & Spl. Commitee on Drug proving, CCRH, Govt. of India
- Former Hon. Project Advisor, Central Research Institute of Homoeopathy, Kottayam, Kerala.
- Former Chairman, Board of Examinations in Homoeopathy, Govt. of Kerala.
- Member, Committee of Experts on Homoeopathic Education, Dept. of AYUSH, M/o. H&FW, Govt. of India
- Member, Screening Committee for ROT & CME Programme, Dept. of AYUSH, M/o. H&FW, Govt. of India
- Member, Governing Body & SFC, National Institute of Homoeopathy, Kolkata, Govt. of India
- Advisor, Sarada Krishna Homoeopathic Medical College, Kulasekharam, K.K. Dist., (T.N.)
- Director, Nascent Academy of Homoeopathy, Thiruvananthapuram.
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