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The Supreme Court of India delivered a landmark judgment on January 29th, declaring domicile-based reservations in postgraduate (PG) medical courses unconstitutional. The three-judge bench, comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti, unanimously ruled that such reservations violate Article 14 of the Indian Constitution, which guarantees equality before the law. This decision effectively nullifies state-level quotas based on residency for admission to PG medical programs. The court's reasoning centered on the principle of national domicile, asserting that all citizens of India possess the right to reside and practice their professions anywhere within the country. This fundamental right extends to accessing educational institutions across India, regardless of state boundaries. The justices emphasized that while some degree of domicile-based reservation might be permissible in undergraduate (MBBS) medical courses, the specialized nature of PG medical programs necessitates a merit-based approach, ensuring the selection of the most qualified candidates irrespective of their place of residence. The court explicitly referenced and reaffirmed its stance in previous cases, namely Pradeep Jain and Saurabh Chandra, which established precedents against such discriminatory practices.
Justice Dhulia, reading the court's reasoning, articulated the core principle: 'We are all domiciles in the territory of India. There is nothing like a provincial or state domicile. There is only one domicile. We are all residents of India. We have the right to choose residence anywhere in India and to carry out trade and profession anywhere in the country. Constitution also gives us the right to choose admission in educational institutions across India.' The court’s decision highlighted the importance of meritocracy in the allocation of scarce PG medical seats, emphasizing the societal need for highly skilled specialists. The court acknowledged that a certain level of state-level reservation might be justified in undergraduate medical education. However, they maintained that the implications for specialized healthcare and the potential for limiting access to highly qualified professionals far outweigh any justifications for domicile-based quotas at the postgraduate level. The significance of the ruling reverberates throughout the Indian medical education system, potentially reshaping admission policies and ensuring broader access to postgraduate medical training for deserving students irrespective of their place of origin.
The Supreme Court’s decision in Tanvi Behl v. Shrey Goel and Ors (C.A. No. 9289/2019) provides clarity and consistency in the application of Article 14 within the context of medical education. The judgment, however, includes a crucial caveat. The court clarified that its ruling would not impact students already enrolled in PG medical courses under domicile-based reservation schemes, nor those who have already completed their studies under such schemes. This ensures that the decision does not retroactively disrupt the educational trajectories of those who entered the program under the previously existing regulations. The judgment’s immediate impact will primarily focus on future admissions to PG medical courses, requiring medical institutions and state governments to revise their admission procedures to conform with the Supreme Court's interpretation of Article 14. The decision has far-reaching implications, setting a precedent for the balance between affirmative action and meritocracy in higher education, particularly in fields with significant national relevance like medicine. The long-term consequences will require close monitoring to assess its impact on the distribution of medical professionals across India and on the accessibility of postgraduate medical education for aspirants from various regions. The ruling underscores the judiciary's commitment to upholding constitutional principles and ensuring equal opportunities for all citizens.
The Supreme Court's judgment reinforces the importance of merit-based selection in higher education, particularly in fields as critical as medicine. By invalidating domicile-based reservations in PG medical courses, the court has aligned the selection process with fundamental constitutional rights. The decision, although potentially causing some immediate shifts in admission patterns, ultimately contributes to building a stronger and more equitable healthcare system for India. The case serves as a reminder of the continuing evolution of constitutional interpretation and the judicial role in safeguarding fundamental rights. The judgment is expected to spark debate among stakeholders, including students, educational institutions, and policymakers, prompting a reevaluation of admission policies to align them with the court's interpretation of Article 14 of the Indian Constitution. The long-term consequences will require analysis to understand the ramifications for equitable representation in postgraduate medical education and the distribution of specialists across the country. Further scrutiny will also likely be directed towards examining the justification, if any, for allowing domicile-based reservations in undergraduate medical programs.
Source: Residence-Based Reservation In PG Medical Courses Impermissible, Violates Article 14 : Supreme Court