Ruling Declares State-Based Reservations Unconstitutional
In a landmark decision, the Supreme Court of India has ruled that domicile-based reservations in postgraduate (PG) medical courses are unconstitutional as they violate Article 14 of the Indian Constitution, which guarantees equality before the law. The verdict was delivered by a three-judge bench comprising Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, and Justice SVN Bhatti.
The ruling emphasizes that admissions to PG medical courses should be solely based on merit and that states cannot restrict a portion of their PG medical seats exclusively for domicile candidates.
Court’s Reasoning
Justice Sudhanshu Dhulia, reading the judgment, stated:
“We are all domiciles in the territory of India. There is nothing like a provincial or state domicile. There is only one domicile. We are all residents of India. We have the right to choose residence anywhere in India and to carry out trade and profession anywhere in the country. The Constitution also gives us the right to choose admission in educational institutions across India.”
The bench referred to the Pradeep Jain and Saurabh Chandra cases, reinforcing that the benefit of domicile-based reservation may be allowed only at the MBBS level. However, at the PG level, where specialization is required, reservations based on state domicile violate the constitutional right to equality.
Merit-Based Admissions for PG Courses
The ruling mandates that state quota seats in PG medical courses should be filled purely on the basis of merit in NEET-PG. The court rejected the argument that states should have the right to reserve seats for their residents at the postgraduate level, citing the need for highly skilled doctors and national mobility in medical education.
Impact of the Judgment
While the ruling prohibits future domicile-based reservations in PG medical courses, students currently pursuing PG courses under domicile quota will not be affected. Those who have already availed such reservations and are in the middle of their courses will continue under the existing provisions.
This judgment is expected to have a major impact on state medical counseling policies, compelling states to restructure their PG admission processes in compliance with the Supreme Court’s ruling.
Case Details
The ruling was delivered in the case Tanvi Behl v. Shrey Goel and Others (C.A. No. 9289/2019). Further details are expected once the complete judgment is uploaded.
Key Observations of the Supreme Court
- Domicile-Based Reservation Violates Article 14
- The court reiterated that residence-based reservations in PG medical courses violate the principle of equality and are therefore unconstitutional.
- However, it clarified that reservation based on domicile is permissible for MBBS admissions in some cases, given the need for regional medical education development.
- State Quota Seats Must Be Merit-Based
- The court ruled that state quota seats in PG medical courses must be filled purely on merit, as determined by NEET-PG ranks.
- This eliminates the possibility of regional favoritism or domicile-based preferences in postgraduate medical education.
- Precedents & Legal Framework
- The decision aligns with previous Supreme Court rulings in cases like Pradeep Jain v. Union of India (1984) and Saurabh Chaudri v. Union of India (2003), which upheld merit-based admissions in PG medical courses.
- No Impact on Existing Admissions
- The court clarified that students who have already secured admission under domicile-based quotas in previous academic years will not be affected.
Implications of the Verdict
- End of State-Based PG Reservations: All Indian citizens will now have equal access to PG medical seats across India, irrespective of state domicile.
- Greater Competition & Transparency: Admissions will now be strictly merit-based, reducing regional bias in medical education.
- Policy Changes for State Quotas: States and UTs will need to revise their PG admission policies to comply with the ruling.
Background of the Case
The High Court of Punjab and Haryana had earlier struck down domicile-based reservations for PG medical seats at GMCH, Chandigarh. This affected students who had secured admissions based on Chandigarh’s UT quota, which provided reservations for:
- Candidates who studied at least five years in Chandigarh.
- Candidates whose parents resided in Chandigarh for at least five years.
- Candidates or their parents who owned immovable property in Chandigarh for five years.
Several affected candidates, along with the UT of Chandigarh and GMCH, challenged this ruling in the Supreme Court, leading to the final verdict upholding the High Court’s decision.
Conclusion
With this ruling, the Supreme Court has reinforced merit-based admissions in PG medical courses, ensuring that all students, regardless of domicile, have equal opportunities. While some states may push back against the decision, it sets a clear precedent that residence-based reservations in PG medical education cannot override the principles of equality and meritocracy.
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This decision marks a significant shift towards merit-based medical education in India, ensuring that PG medical seats are accessible to all qualified candidates, irrespective of their state of residence. It reinforces the principle that medical education should prioritize excellence over geographical boundaries, ultimately benefiting healthcare standards across the country.