New Delhi, Jan 30: The Supreme Court of India, in a landmark ruling on Wednesday, declared that residence-based reservation in Post Graduate (PG) medical courses under the state quota is constitutionally invalid.
A bench led by Justice Hrishikesh Roy, along with Justices Sudhanshu Dhulia and S.V.N. Bhatti, held that providing domicile or residence-based reservations in PG medical courses is impermissible and violates the fundamental rights enshrined in the Constitution.
Violation of Constitutional Equality
The apex court observed that such reservations contradict the principles of citizenship and equality, as guaranteed under Article 14 of the Indian Constitution. While a reasonable degree of institutional preference is allowed in PG medical courses, residence-based reservation in these courses is not legally tenable.
“We must also remember that, to a reasonable degree, residence-based reservation in a state is permissible for MBBS courses, but the same reservation for PG courses is not permissible,” the bench noted in its ruling.
The court cited its previous judgments, emphasizing that merit should be the primary criterion for admissions at the PG level. While undergraduate (MBBS) medical courses may allow limited residence-based reservation, PG courses require a stricter merit-based approach to ensure the availability of highly skilled specialists in the medical field.
The Chandigarh Case and High Court Verdict
The case in question involved the Chandigarh Government Medical College and Hospital (GMCH), where 64 PG medical seats under the state quota were reserved either for ‘residents’ of Chandigarh or for candidates who completed their MBBS from the same institution. The institution’s prospectus provided a broad definition of ‘residents,’ including those who studied in Chandigarh for at least five years or whose parents owned property in the Union Territory for five years.
This provision was challenged before the Punjab and Haryana High Court, which ruled that the reservation was based on a long-rejected principle of domicile and was legally unsound. The Supreme Court upheld this verdict, stating that domicile-based reservations beyond a reasonable limit infringe upon the fundamental rights of students from other states.
Fundamental Right to Equal Opportunity
Reaffirming the principle of equal opportunity, the Supreme Court stressed that all Indian citizens have the right to reside, study, and practice a profession anywhere in the country. The ruling emphasized that permitting residence-based reservation at the PG level would unjustly discriminate against students from different states and violate their fundamental rights.
“If such a reservation is permitted, then it would be an invasion on the fundamental rights of several students, who are being treated unequally simply for the reason that they belong to a different state in the Union!” the bench observed.
The court concluded that state quota seats in PG medical courses, apart from a reasonable number of institution-based reservations, must be filled strictly based on merit as determined by national-level examinations.
Implications of the Verdict
This ruling is expected to have far-reaching implications for medical education policies across India. States implementing residence-based quotas in PG medical admissions may need to revise their policies in light of the Supreme Court’s decision. The judgment reinforces the emphasis on meritocracy in specialized medical education while upholding the constitutional principles of equality and non-discrimination.
Disclaimer: This news article is based on the Supreme Court’s recent ruling and does not constitute legal advice. Readers are encouraged to refer to official sources for detailed information and further developments. The views expressed in the ruling are those of the Supreme Court and not of this publication.