Supreme Court Strikes Down Domicile-Based Reservation for PG Medical Courses

New Delhi – The Supreme Court has ruled that domicile or residence-based reservations for postgraduate (PG) medical course admissions under the State Quota violate the right to equality enshrined in Article 14 of the Indian Constitution. The three-judge Bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti held that admissions must be based purely on merit, not residence.

Key Judgment Highlights

The Court emphasized that India has a unified domicile status and that reservations based on residence at the postgraduate level are unconstitutional. While some domicile-based reservations may be permissible at the MBBS level, extending the same to PG medical courses is discriminatory.

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“We are all domiciled in India, and there is no provincial domicile. This gives us the right to pursue trade across the country. Reservation in higher education based on residence violates Article 14,” the Supreme Court observed.

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However, the judgment will not impact reservations already granted under domicile-based categories before this ruling.

Background of the Case

The verdict stems from a 2019 reference made by a two-judge Bench, which sought clarity on whether domicile-based reservations for PG medical admissions within the State Quota were constitutionally valid. The Supreme Court examined key questions, including:

  1. Whether domicile-based reservation for PG medical courses within State Quotas is unconstitutional?
  2. If permissible, what should be the extent and manner of such reservations, particularly in States/UTs with a single medical college?
  3. If impermissible, how should State Quota seats—beyond institutional preference—be filled?
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The case arose from appeals challenging a Punjab and Haryana High Court ruling, which had struck down domicile-based reservations in PG medical admissions at Government Medical College and Hospital, Chandigarh. The High Court ruled that certain provisions in the Chandigarh UT Pool prospectus were unconstitutional.

Arguments Before the Supreme Court

Senior Advocate Nidhesh Gupta, representing private respondents, contended that domicile-based reservations were impermissible, a stance that the Supreme Court ultimately upheld.

Implications of the Ruling

This landmark judgment reinforces merit-based admissions in postgraduate medical education, ensuring that state residency cannot be a criterion for PG medical seats under the State Quota.

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The decision is expected to impact State admission policies and could lead to a re-evaluation of reservation norms in medical education across India.

(Copy of Judgment will be uploaded soon)

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