Supreme Court strikes down domicile-based reservation for PG medical admissions

The Supreme Court has declared that state-level domicile or residence-based reservations for postgraduate (PG) medical admissions violate the constitutional right to equality under Article 14. The verdict came in response to the case Tanvi Behl v. Shreya Goyal.

A Bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti emphasized that admissions should be determined solely on merit. The Court underscored that all Indian citizens share a common domicile across the country, allowing them to pursue opportunities without provincial restrictions. While certain reservations based on residence may be permitted at the undergraduate (MBBS) level in exceptional cases, extending such policies to postgraduate medical education was deemed unconstitutional.

However, the ruling clarified that the decision would not impact reservations already granted under the residence-based category before the judgment.

The case originated from a reference made in 2019 by a two-judge Bench, which sought clarity on key legal questions, including:

1. Whether domicile or residence-based reservations in PG medical admissions under the State Quota are constitutionally valid.

2. If such reservations were permissible:

- To what extent and in what manner should they be implemented?

- How should they be applied in states or Union Territories with only one medical college, considering that NEET rankings determine admissions?

3. If such reservations were found unconstitutional, how should State Quota seats—beyond institutional preference quotas—be allocated?

These issues arose from appeals against a Punjab and Haryana High Court decision concerning postgraduate medical admissions at the Government Medical College and Hospital in Chandigarh. The High Court had invalidated provisions in the college’s admission prospectus that reserved seats under the UT Chandigarh Pool based on domicile or residence.

With this ruling, the Supreme Court has reinforced the principle that merit should be the sole criterion for postgraduate medical admissions, ensuring uniformity and equal opportunity across India.