Supreme Court Strikes Down Domicile-Based Reservation in PG Medical Courses
The Hon’ble Supreme Court of India, in the case of Tanvi Behl v. Shrey Goel & Others, ruled that domicile-based reservations for PG medical admissions are unconstitutional as they violate Article 14 of the Indian Constitution.
A bench comprising Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, and Justice SVN Bhatti declared that residence-based reservation in PG medical courses is impermissible within the State Quota. The Court reiterated that admissions must be based solely on merit as determined by the NEET examination.
Key Judgment Highlights
The Court reaffirmed its stance from previous landmark rulings (Pradeep Jain v. Union of India and Saurabh Chaudri v. Union of India), stating that PG medical education requires merit-based selection to ensure the availability of highly skilled specialists across India.
While acknowledging that some degree of reservation may be permissible at the undergraduate (MBBS) level, the Court emphasized that PG medical courses require the highest standard of meritocracy.
The ruling does not affect students currently enrolled under domicile-based reservations or those who have already graduated under such provisions.
Background and Legal Precedents
The Supreme Court was hearing appeals against a Punjab and Haryana High Court judgment, which had struck down residence-based reservation in PG medical admissions at Government Medical College, Chandigarh. The case was referred to a larger bench in 2019, seeking clarity on the following issues:
Whether domicile-based reservations in PG medical admissions are constitutionally valid.
If permissible, what should be the extent and manner of such reservations?
If impermissible, how should State Quota seats be allocated?
The Court referred to key judgments, including:
Jagadish Saran v. Union of India (1980)
Dr. Pradeep Jain v. Union of India (1984)
Saurabh Chaudri v. Union of India (2003)
Implications of the Ruling
This landmark judgment reinforces the principle of merit-based admissions in PG medical courses, ensuring that highly qualified doctors serve the nation irrespective of domicile. It upholds the constitutional guarantee of equal opportunity and eliminates regional barriers in specialized medical education.