The Chhattisgarh High Court has declared Rule 11(a) and Rule 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 as ultra vires and unconstitutional. The Division Bench, comprising Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru, ruled that residence-based reservation in Post Graduate (PG) medical courses violates Article 14 of the Constitution of India. The Court directed the State not to discriminate between candidates based on the categories mentioned in the impugned rules.
Summary of Legal Issue and Outcome
The core legal issue before the Court was the constitutional validity of Rule 11(a) and Rule 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, which provided preference in admission to State quota seats for candidates who obtained their MBBS degrees from medical colleges within the State of Chhattisgarh. The High Court allowed the writ petition, quashing the said rules on the grounds that residence-based reservation in PG medical courses is impermissible and violates the equality clause of the Constitution.
Background of the Case
The petitioner, Dr. Samriddhi Dubey, is a permanent resident of Chhattisgarh who completed her High School education in Bilaspur. She obtained her MBBS degree from VMKV Medical College and Hospital, Salem, Tamil Nadu, based on her All India Rank in NEET (UG) 2018. She completed her internship in April 2024 and is registered with both the Tamil Nadu Medical Council and the Chhattisgarh Medical Council.
The petitioner appeared for the NEET (PG)-2025 examination and secured an All India Rank of 75068. Subsequently, the State Government notified the Chhattisgarh Medical Post Graduate Admission Rules, 2025 to regulate admissions to PG medical courses. Rule 11 of these rules established a preference system:
- Rule 11(a): Provided that for seats available in the State quota, admission would be given first to candidates who obtained their MBBS degree from a medical college affiliated with Pt. Deendayal Upadhyay Smriti Swasthya Vigyan Evam Ayush University, Chhattisgarh, or to serving candidates.
- Rule 11(b): Stated that only if seats remained vacant after admitting candidates under Rule 11(a), would admission be granted to candidates who obtained their MBBS degrees from medical colleges outside Chhattisgarh.
The petitioner challenged these rules, contending that they effectively created 100% reservation for candidates who graduated from institutions within Chhattisgarh, thereby discriminating against permanent residents of the State who obtained their degrees from universities outside the State.
Arguments of the Parties
The Petitioner’s Arguments: Mr. Rajeev Shrivastava, Senior Advocate appearing for the petitioner, argued that Rule 11(a) and 11(b) of the 2025 Rules were “ultra vires / unconstitutional being violative of the Article 14 of the Constitution of India.” He submitted that the rules created an “unjustifiable classification” between residents of the State and others based solely on the university from which they obtained their degree.
The counsel relied heavily on the Supreme Court’s recent judgment in Dr. Tanvi Behl v. Shrey Goel & Others (2025 SCC OnLine SC 180), arguing that the Apex Court had clearly held that residence-based reservation in PG medical courses is impermissible. He contended that allowing such reservation would be an invasion of fundamental rights and a denial of equality before the law.
The Respondent’s (State) Arguments: Mr. Shashank Thakur, Deputy Advocate General for the State, defended the rules, arguing that the petitioner lacked grounds to challenge their constitutionality. He submitted that unlike the 2021 Rules, which explicitly provided preference based on domicile, the 2025 Rules provided “institutional preference.”
He argued that Rule 11(a) gave preference to candidates who completed their MBBS from colleges affiliated with the State AYUSH University, regardless of their domicile. He contended that many candidates admitted to MBBS courses in these colleges under the All India Quota were residents of other states, and thus, the rule did not discriminate based on residence but rather provided valid institutional preference.
Court’s Analysis and Observations
The High Court focused its analysis on whether the reservation provided under the impugned rules amounted to impermissible residence-based reservation. The Bench referred extensively to the Supreme Court’s decision in Dr. Tanvi Behl, which analyzed previous judgments in Pradeep Jain v. Union of India and Saurabh Chaudri v. Union of India.
The Court quoted the Supreme Court in Dr. Tanvi Behl:
“The benefit of ‘reservation’ in educational institutions including medical colleges to those who reside in a particular State can be given to a certain degree only in MBBS courses… But considering the importance of specialists doctors’ in PG Medical Course, reservation at the higher level on the basis of ‘residence’ would be violative of Article 14 of the Constitution of India.”
The judgment further highlighted the Apex Court’s observation that:
“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 reasons that they belong to a different State in the Union! This would be a violation of the equality clause in Article 14 of the Constitution and would amount to a denial of equality before the law.”
The High Court also cited the Supreme Court’s observation in Jagdish Saran, emphasizing the importance of merit at higher levels of education:
“To devalue merit at the summit is to temporise with the country’s development in the vital areas of professional expertise… Of course, this unrelenting strictness in selecting the best may not be so imperative at other levels where a broad measure of efficiency may be good enough and what is needed is merely to weed out the worthless.”
The Bench noted that an identical issue had been decided by the Madhya Pradesh High Court in Sawan Bohra & Another v. State of M.P. & Others (WP No. 38169/2025) on November 19, 2025. The Court observed, “Since the issue involved in this petition is identical to that of Sawan Bohra (supra), we are of the considered view that no distinct view can be taken than what has been taken by the Madhya Pradesh High Court in the said case.”
Decision
The High Court allowed the writ petition. The Division Bench held:
“In view of the proposition of law as laid down by the Apex Court in Dr. Tanvi Behl (supra), Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 are quashed being ultra vires and violative of Article 14 of the Constitution of India and the State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025.”
Case Details:
- Case Title: Dr. Samriddhi Dubey v. The State of Chhattisgarh & Others
- Case No.: WPC No. 5937 of 2025
- Bench: Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru
