“In a significant ruling, the Supreme Court on Wednesday declared that domicile-based reservations for postgraduate medical admissions are unconstitutional. The court stated that such reservations violate Article 14 of the Constitution, which ensures equality. A bench of Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti pronounced that residence-based reservations in PG medical courses clearly contravene the principles of equality under Article 14.”
While delivering the judgment, Justice Dhulia emphasized, “We are all domiciles of India; there is no separate provincial or state domicile. There is only one domicile, and we are all residents of India. We have the right to choose our residence anywhere in the country and freely pursue trade and profession. The Constitution also guarantees us the right to seek admission to educational institutions throughout India.”
The judgment sets an important precedent, ensuring that postgraduate (PG) medical admissions under state quotas must be determined solely by merit in the National Eligibility cum Entrance Test (NEET). While the bench acknowledged that domicile-based reservations could be allowed for undergraduate (MBBS) admissions, it firmly ruled that applying such reservations to PG courses—where specialization and expertise are essential—would be unconstitutional.
“Given the significance of specialised doctors in PG medical courses, residence-based reservation at this level would violate Article 14 of the Constitution,” Justice Dhulia added.
However, the bench clarified that the ruling will not affect existing domicile reservations. Students currently enrolled in PG courses or those who have already graduated under such reservations will not be impacted.
In 2019, a two-judge Supreme Court bench, in the case of Dr. Tanvi Behl (SV) vs. Shrey Goel and Others, addressed appeals against a Punjab and Haryana High Court ruling that deemed domicile reservations in PG medical admissions unconstitutional.
Given the importance of the issue, especially since Chandigarh has only one medical college, the bench referred the matter to a larger bench for a final decision. The three-judge bench has now clarified that PG medical admissions will be merit-based and that states cannot impose restrictive domicile criteria.
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