The ruling was made in response to a reference from 2019, where a two-judge Bench had sought clarity on whether domicile-based reservations for PG medical courses in state quota seats were legally valid. The following key questions were raised:
NEW DELHI: The Supreme Court of India ruled on Wednesday(29th Jan) that reserving seats in postgraduate (PG) medical courses based on domicile or residence within a state is against the right to equality under Article 14 of the Constitution. The Court emphasized that admissions must be strictly based on merit.
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A three-judge Bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti delivered this important judgment. The Court made it clear that domicile-based reservations cannot be allowed at the PG level in medical education.
“We are all domicile in India and there is no provincial domicile etc. … This gives us a right to pursue trade across India. 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 basis of residence is violative of Article 14.”
However, the Court clarified that the ruling will not affect reservations that have already been granted under the residence-based category.
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The ruling was made in response to a reference from 2019, where a two-judge Bench had sought clarity on whether domicile-based reservations for PG medical courses in state quota seats were legally valid. The following key questions were raised:
- Is it legally invalid to provide domicile or residence-based reservations for admission to PG medical courses within the state quota?
- If such reservations are allowed, what should be their extent and method of implementation?
- If domicile-based reservations are permitted, how should they be applied in states or union territories that have only one medical college?
- If such reservations are invalid, how should state quota seats, apart from institutional preference seats, be allocated?
The case originated from an appeal against a decision of the Punjab and Haryana High Court concerning PG medical admissions at the Government Medical College and Hospital, Chandigarh. The High Court had declared certain provisions in the medical college’s prospectus invalid, specifically those that provided domicile-based reservations under the UT Chandigarh Pool.
By ruling in favor of merit-based admissions, the Supreme Court has reinforced the principle that higher education opportunities, particularly at the PG medical level, should not be restricted based on residence but should be accessible to all based on their performance in NEET.
CASE TITLE:
TANVI BEHL v. SHREY GOEL AND ORS | C.A. No. 9289/2019
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