In a significant ruling, the Supreme Court of India has struck down the practice of restricting meritorious reserved category candidates from securing seats in the unreserved category under horizontal reservations. The case, Ramnaresh @ Rinku Kushwah & Ors. v. State of Madhya Pradesh & Ors. (Civil Appeal No. ___ of 2024, arising out of SLP(C) No. 2111 of 2024), dealt with the contentious issue of allocation of MBBS seats in Madhya Pradesh. The appellants, all meritorious students from reserved categories, challenged the Madhya Pradesh government’s methodology in applying horizontal reservation that prevented them from being considered under the unreserved category despite their merit.
Legal Issues Involved
The central legal issue in the case revolved around the interpretation of horizontal and vertical reservations and whether a meritorious candidate from a reserved category can be denied a seat in the unreserved category under the horizontal reservation scheme. The appellants argued that the state government’s method of further sub-classifying reserved candidates into UR-GS, SC-GS, ST-GS, OBC-GS, and EWS-GS categories was illegal and against the established principles laid down by the Supreme Court in previous judgments, particularly in Saurav Yadav and Others v. State of Uttar Pradesh and Others.
Arguments Presented
Senior Counsel Shri K. Parameshwar, representing the appellants, argued that the policy applied by the Madhya Pradesh government was erroneous and resulted in less meritorious candidates from the unreserved government school (UR-GS) category securing admission while more meritorious candidates from reserved categories were denied their rightful seats. He emphasized that this practice violated the principles established by the Supreme Court in earlier cases, which clearly state that meritorious candidates from reserved categories should be considered for unreserved seats if they meet the merit criteria.
On the other hand, Shri Nachiketa Joshi, the Additional Advocate General (AAG) representing the State of Madhya Pradesh, defended the state’s policy, arguing that the sub-classification within horizontal reservations was justified and necessary to ensure representation across all categories.
Supreme Court’s Observations and Judgment
The bench comprising Justice B.R. Gavai and Justice K.V. Viswanathan delivered the judgment on August 20, 2024. The Court held that the state’s methodology of compartmentalizing categories within horizontal reservations and restricting the migration of meritorious reserved category candidates to unreserved seats was “totally unsustainable.” The Court reaffirmed the principles laid down in Saurav Yadav and reiterated that horizontal reservations should not be treated as rigid slots that preclude meritorious candidates from competing in the unreserved category.
Justice B.R. Gavai, writing for the bench, observed:
“The open category is open to all, and the only condition for a candidate to be shown in it is merit, regardless of whether reservation benefit of either type is available to her or him. Restricting meritorious reserved candidates from unreserved seats is not only unjust but also contravenes the principles of meritocracy.”
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Further, the Court directed the Madhya Pradesh government to admit the appellants in the next academic session (2024-25) for the MBBS course against the seats reserved for the UR-GS category. The judgment also quashed the orders passed by the Madhya Pradesh High Court that had upheld the state government’s policy.
