Supreme Court Strikes Down Residence-Based Reservation in PG Medical Courses: “Domicile-Based Reservation Violates Article 14; Merit Must Prevail Over Regional Preference”

Court’s Decision

The Supreme Court ruled that domicile or residence-based reservations for PG Medical Courses are unconstitutional and impermissible. The Court held that such reservations violate Article 14 of the Constitution as they create artificial barriers that deny meritorious students the opportunity to secure admission based solely on their NEET ranking.

The Court reaffirmed that “providing for domicile or residence-based reservation in PG Medical Courses is constitutionally impermissible and cannot be done.” However, the institutional preference (where students who completed their MBBS from the same college receive preference) was upheld as a permissible classification.

The Supreme Court thus upheld the Punjab and Haryana High Court’s ruling, which had struck down the residence-based reservation in the Government Medical College and Hospital, Chandigarh, declaring it unconstitutional.

Facts of the Case

1. Admission Policy of Government Medical College and Hospital, Chandigarh (GMCH)
   • The case revolved around the admission process for PG Medical Courses at GMCH.
   • The college had 64 PG Medical seats under the State Quota, which were divided into two categories:
     • Institutional Preference Pool (32 seats) – Reserved for candidates who had completed their MBBS from GMCH.
     • UT Chandigarh Pool (32 seats) – Reserved for candidates who satisfied residence-based criteria, which included:
       • Studying in Chandigarh for at least five years before the last date of application.
       • Their parents residing in Chandigarh for at least five years before the last date of application.
       • Their parents owning immovable property in Chandigarh for at least five years before the last date of application.
2. Challenge Before the High Court
   • Several petitions were filed before the Punjab and Haryana High Court, challenging the residence-based quota (UT Chandigarh Pool), arguing that it was unconstitutional and in direct violation of Supreme Court rulings.
   • The petitioners contended that all 64 seats were effectively reserved for Chandigarh students, denying meritorious candidates from other states their rightful opportunity based on merit.
3. High Court’s Ruling
   • The High Court struck down the residence-based quota, declaring clauses 2B(i), (ii), and (iii) of the GMCH prospectus unconstitutional.
   • The Court directed GMCH to fill the seats based solely on merit in the NEET Examination.
4. Appeal Before the Supreme Court
   • The High Court’s ruling was challenged in the Supreme Court.
   • On May 9, 2019, the Supreme Court granted an interim stay, allowing the admissions to proceed based on the existing residence-based criteria, but made it subject to the final outcome of the case.

Issues Before the Supreme Court

1. Is domicile/residence-based reservation in PG Medical Courses within the State Quota constitutionally valid?
2. If residence-based reservation is permissible, what should be the extent and manner of its implementation, particularly in Union Territories with only one medical college?
3. If residence-based reservation is impermissible, how should the State Quota seats be filled?

Petitioner’s Arguments

• The petitioners challenged the reservation policy, arguing that:
  • Residence-based reservation violates Article 14 (Right to Equality) as it denies equal opportunity to meritorious candidates from outside Chandigarh.
  • Supreme Court precedents in Jagadish Saran v. Union of India (1980), Dr. Pradeep Jain v. Union of India (1984), and Saurabh Chaudri v. Union of India (2003) had already established that residence-based reservations in PG Medical Courses are unconstitutional.
  • At the postgraduate level, merit must be the primary criterion for admission, and reserving seats based on residence dilutes the merit principle.
  • The institutional preference quota was permissible, but reserving seats based on residence created an arbitrary classification without a rational basis.

Respondent’s Arguments

• The State of Chandigarh defended the residence-based quota, arguing that:
  • The State has a legitimate interest in ensuring that local students have better access to PG Medical Courses.
  • The State invests substantial resources in medical education, and providing a quota for local students ensures a return on investment in terms of local healthcare services.
  • They argued that the Constitution does not explicitly prohibit residence-based reservations under Article 15, and therefore, states should be allowed to frame their own policies.

Analysis of the Law

The Supreme Court examined whether residence-based reservations violate Articles 14 and 15 of the Constitution.

1. Article 14 (Right to Equality)
   • Any classification for reservation must have a rational nexus to the objective sought to be achieved.
   • The Court observed that while institutional preference is justified, residence-based reservations create an artificial distinction that denies meritorious candidates equal access.
2. Article 15 (Prohibition of Discrimination on Grounds of Place of Birth)
   • The Court noted that while Article 15 does not explicitly prohibit residence-based reservations, any classification must still pass the test of reasonableness under Article 14.
3. Article 16 (Prohibition of Discrimination in Public Employment)
   • Even in public employment, residence-based reservations are generally impermissible.
   • The Court questioned why, if residence is not a valid ground for public employment, it should be allowed for PG medical admissions.

Precedent Analysis

The Supreme Court relied on several landmark judgments:

1. Jagadish Saran v. Union of India (1980)
   • Held that institution-based reservations were permissible, but domicile-based reservations were discouraged.
2. Dr. Pradeep Jain v. Union of India (1984)
   • Explicitly struck down domicile-based reservations in PG medical courses, holding that merit must be the sole criterion at higher levels of education.
3. Saurabh Chaudri v. Union of India (2003)
   • A Constitution Bench reaffirmed Pradeep Jain, stating that residence-based reservations in PG Medical Courses are impermissible.

The Court also cited Magan Mehrotra v. Union of India (2003), Nikhil Himthani v. State of Uttarakhand (2013), and Vishal Goyal v. State of Karnataka (2014), all of which reaffirmed that residence-based reservations violate Article 14.

Court’s Reasoning

• The Court firmly rejected the concept of state-based domicile for educational purposes, stating that “every citizen of India carries only one domicile – the Domicile of India.”
• The only permissible form of reservation in PG Medical Courses is institutional preference.
• The Court criticized the growing trend of regionalism and “sons of the soil” policies, warning that such reservations could fragment national unity.
• At the PG level, merit must be the overriding factor, as PG medical education involves specialized training essential for national healthcare.

Conclusion

• The Supreme Court struck down residence-based reservations for PG medical admissions as unconstitutional.
• The institutional preference quota (32 seats) was upheld, but the UT Chandigarh Pool (32 seats) was declared invalid.
• The Court reaffirmed the principle that PG medical admissions should be based on merit, not residence.
• However, students who had already secured admission under the residence quota and had completed their courses were not affected due to the principle of equity.

Implications

• This ruling establishes a nationwide precedent against residence-based reservations in PG medical courses.
• States can no longer reserve seats for “residents” in PG medical colleges.
• Merit-based admissions will be enforced in higher medical education, ensuring that the most competent students secure specialized training.

This judgment reinforces the Supreme Court’s commitment to meritocracy, national integration, and the constitutional principle of equal opportunity.

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