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The Supreme Court of India delivered a landmark judgment on Wednesday, declaring domicile-based reservation policies for postgraduate (PG) medical courses unconstitutional. This decision, reached by a three-judge bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and S V N Bhatti, has significant implications for medical education and the principles of equality enshrined in the Indian Constitution. The court's ruling stems from a reference made by a division bench, prompted by appeals against a Punjab and Haryana High Court decision concerning admissions at the Government Medical College and Hospital in Chandigarh. The High Court had invalidated certain provisions implemented by the medical college regarding its admission process. The Supreme Court's judgment emphasizes the fundamental right of all Indian citizens to pursue education and profession across the country, irrespective of their domicile state. The court articulated that while some degree of reservation might be permissible in undergraduate medical courses (MBBS), extending such reservation policies to postgraduate medical courses is a violation of Article 14 of the Constitution, which guarantees equality before the law.
The core argument presented by the Supreme Court hinges on the principle of equality. The justices argued that permitting domicile-based reservations in PG medical courses would create an unequal playing field, discriminating against students from states other than the one offering the reservation. This, the court reasoned, constitutes a violation of Article 14 by treating students unequally solely based on their state of origin. The court highlighted that the common bond of citizenship entitles all Indians to the right to reside anywhere in the country, pursue any profession, and seek admission to educational institutions nationwide. Restricting access to postgraduate medical education based on domicile is therefore deemed to be an infringement upon these fundamental rights. The court specifically addressed the case of the Government Medical College and Hospital, Chandigarh, which had 64 PG seats in its state quota, with a portion reserved for residents of Chandigarh or those who completed their MBBS from the same college. The Supreme Court upheld the High Court's decision, finding that reserving 32 seats based on residence was unlawful. However, the court clarified that 32 seats could be reserved based on institutional preference.
The Supreme Court's decision clarifies the permissible limits of reservation policies in the context of postgraduate medical education. While acknowledging the importance of institutional reservations to a certain extent, the court emphasized that the remaining state quota seats must be filled solely on the basis of merit, as determined by all-India examinations. This ruling aims to ensure a level playing field for all aspiring doctors, irrespective of their place of residence. The judgment is crucial because it reinforces the constitutional mandate of equality and challenges the justification for domicile-based reservation policies in specialized medical training. This creates a precedent that might have far-reaching consequences for other states and their admission policies to postgraduate courses in various fields of study, not just medicine. The court clarified that its declaration of impermissibility of residence-based reservation in PG courses would not affect the reservations already granted or those students who have already completed or are currently pursuing PG courses in the aforementioned Government Medical College, Chandigarh.
The impact of this Supreme Court decision extends beyond the immediate case. It sets a crucial precedent that will undoubtedly influence future legal challenges to similar reservation policies across various states in India. Institutions offering PG medical courses will need to review their admission procedures to ensure compliance with the court's ruling, potentially requiring significant changes to existing quota systems. Furthermore, the decision underscores the ongoing debate regarding the balance between affirmative action and the principle of equality in the context of higher education in India. This ruling will likely stimulate further discussions and judicial interpretations on the complexities of implementing reservation policies while upholding constitutional guarantees of equality and merit-based selections. The potential legal challenges and ensuing debates surrounding the implementation of this ruling in different contexts are likely to unfold in the coming months and years.
Source: Domicile-based reservation in PG medical courses by state unconstitutional, SC holds