In a significant ruling, the Chhattisgarh High Court has declared Rule 4(1)(d)(i) of the Chhattisgarh Ayush Graduate Course Admission Rules, 2023, as ultra vires, stating that the fixation of a 50% domicile quota for local students in unaided minority institutions violates constitutional rights. The case was brought before the court by Mahaveer College of Ayurvedic Science, Rajnandgaon, and the Youth Foundation of India, challenging the constitutionality of the rule. The petitioners were represented by Advocate Ms. Surya Kawalkar Dangi, while the State was defended by Additional Advocate General Mr. Yashwant Singh Thakur.
Background of the Case
Mahaveer College of Ayurvedic Science, an unaided minority institution, was established in 2017 to impart education in the Bachelor of Ayurvedic Medicine and Surgery (BAMS) course. The institution is affiliated with Pandit Deendayal Upadhyay Medical Science and Ayush University, Raipur, and caters primarily to students from the Jain minority community. In 2023, the Chhattisgarh government introduced new admission rules under the Chhattisgarh Ayush Graduate Course Admission Rules, 2023. Under Rule 4(1)(d)(i), the State mandated that 50% of the available seats in minority institutions be reserved for students who are domiciles of Chhattisgarh, specifically from the local Jain community.
Mahaveer College challenged this rule on the grounds that it violated their constitutional rights under Article 30(1), which grants minority institutions the autonomy to manage their admissions without government interference in the form of a quota system.
Key Legal Issues
The central issue before the court was whether the State of Chhattisgarh could impose a 50% domicile quota in an unaided minority institution, thereby restricting the institution’s freedom to admit students of its choice. The petitioners argued that such a quota encroached on their constitutional right to establish and administer educational institutions without undue interference from the government. They relied on previous landmark judgments from the Supreme Court, such as T.M.A. Pai Foundation v. State of Karnataka and P.A. Inamdar v. State of Maharashtra, where the court had held that unaided minority institutions could not be compelled to reserve seats for State-nominated candidates.
The State, however, contended that the reservation was essential to provide opportunities to local minority students and was within its legislative competence. They argued that the rule was framed to ensure the upliftment of local communities, citing the government’s power to regulate admissions in educational institutions to ensure equitable access to education.
Court’s Decision
The Division Bench, comprising Chief Justice Shri Ramesh Sinha and Justice Shri Ravindra Kumar Agrawal, ruled in favor of the petitioners, declaring Rule 4(1)(d)(i) of the Chhattisgarh Ayush Graduate Course Admission Rules, 2023, as ultra vires and unconstitutional. The court held that the State cannot enforce its domicile policy on unaided minority institutions by imposing a quota system that limits the institution’s autonomy in managing its admissions.
In its judgment, the court quoted the landmark Supreme Court ruling in P.A. Inamdar v. State of Maharashtra, where it was held that “neither the policy of reservation can be enforced by the State nor any quota or percentage of admissions can be carved out to be appropriated by the State in a minority or non-minority unaided educational institution.”
The court further observed that imposing a quota for domicile students violated the rights of minority institutions to admit students of their choice, including students from outside the State. The Bench highlighted that minority institutions have the right to maintain their character as minority-run institutions and that any excessive imposition of State rules would dilute this character.
Key Observations
The court made critical observations regarding the autonomy of minority institutions, stating that the imposition of a 50% domicile quota amounted to “nationalisation of seats,” which has been expressly disapproved by the Supreme Court in multiple cases. The judgment emphasized that such quotas constitute an encroachment on the institution’s right to administer its affairs and undermined the intent of Article 30(1) of the Constitution.
The court concluded by stating that while the State may implement regulatory measures to ensure standards in education, it cannot compel unaided minority institutions to follow a reservation system that limits their constitutional freedoms.
Case Details:
– Case Number: WPC No. 4327 of 2023
– Parties: Mahaveer College of Ayurvedic Science and Youth Foundation of India vs. State of Chhattisgarh
– Bench: Chief Justice Shri Ramesh Sinha and Justice Shri Ravindra Kumar Agrawal
– Petitioners’ Counsel: Ms. Surya Kawalkar Dangi
– State’s Counsel: Mr. Yashwant Singh Thakur (Additional Advocate General)
