In a landmark ruling, the Supreme Court on Wednesday declared domicile or residence-based reservations for postgraduate medical admissions under the State Quota unconstitutional, citing violations of Article 14 of the Constitution. The verdict was delivered by a three-judge Bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti in the case of Tanvi Behl v. Shreya Goyal.
“No Provincial Domicile” in India, Says SC
Emphasizing the principle of equal opportunity, the Bench observed:
“We are all domiciled in India, and there is no provincial domicile. This gives us a right to pursue trade across India. The benefit of reservation in education to those who reside in certain areas can be given only in MBBS in some cases. But reservation in higher level on the basis of residence is violative of Article 14.”
The ruling came in response to a 2019 reference by a two-judge Bench regarding the constitutional validity of domicile-based reservations in PG medical courses.
Legal Questions Addressed
The Court addressed three key issues:
- Whether domicile-based reservations in PG medical admissions within the State Quota are constitutionally valid.
- If permissible, what should be the extent and manner of such reservations, considering the NEET-based admission process.
- If unconstitutional, how should State Quota seats, aside from institutional preference seats, be allocated.
The matter arose from a dispute over PG admissions at Government Medical College and Hospital, Chandigarh. The Punjab and Haryana High Court had previously invalidated certain provisions in the institution’s prospectus that allowed domicile-based reservations under the UT Chandigarh Pool.
No Impact on Past Admissions
While striking down the policy, the Supreme Court clarified that the judgment would not affect admissions already granted under the domicile-based category.
This decision reinforces the principle that postgraduate medical admissions must be solely merit-based, ensuring a level playing field for all candidates across the country.
Case: Tanvi Behl vs Shreya Goyal – Available on LAWFYI.IO