Case Note & Summary
The case arose from the Union Territory of Chandigarh, which has only one medical college, Government Medical College and Hospital, Chandigarh. The prospectus for PG Medical Course admissions for the academic year 2019-2020 divided the 64 State Quota seats into two pools: Institutional Preference Pool (32 seats for those who passed MBBS from the same college) and UT Chandigarh Pool (32 seats for candidates fulfilling residence-based criteria, such as studying in Chandigarh for 5 years, parents residing in Chandigarh for 5 years, or parents holding immovable property in Chandigarh for 5 years). Petitions were filed before the Punjab and Haryana High Court challenging these residence-based criteria as violative of Article 14 and contrary to Supreme Court precedents. The High Court declared the residence-based clauses invalid and unconstitutional, directing that seats be filled based on NEET merit. The decision was challenged in the Supreme Court, which stayed the High Court's order but referred the matter to a larger Bench. The Supreme Court framed three questions: (1) whether residence-based reservation in PG Medical Courses is constitutionally invalid; (2) if permissible, the extent and manner; and (3) if impermissible, how State Quota seats should be filled. The Court answered question 1 in the affirmative, holding that residence-based reservation is impermissible, relying on the Constitution Bench decision in Saurabh Chaudri v. Union of India (2003) 11 SCC 146, which followed Dr. Pradeep Jain v. Union of India (1984) 3 SCC 654. The Court noted that institutional preference is permissible to a reasonable extent as held in Jagadish Saran v. Union of India (1980) 2 SCC 768, but residence-based reservation is not. Consequently, questions 2(a) and 2(b) were not answered. For question 3, the Court directed that State Quota seats, other than permissible institutional preference seats, must be filled purely on the basis of merit in the NEET examination. The Court upheld the High Court's decision and dismissed the appeals.
Headnote
A) Constitutional Law - Reservation - Residence-Based Reservation in PG Medical Courses - Article 14 of the Constitution of India - The Court held that providing for domicile or residence-based reservation in admission to PG Medical Courses within the State Quota is constitutionally invalid and impermissible, as it violates Article 14. The Court relied on the Constitution Bench decision in Saurabh Chaudri v. Union of India (2003) 11 SCC 146, which followed Dr. Pradeep Jain v. Union of India (1984) 3 SCC 654, holding that residence-based reservation is not permissible for PG Medical Courses. (Paras 5-10) B) Constitutional Law - Institutional Preference - PG Medical Courses - Article 14 of the Constitution of India - The Court noted that institutional preference (reservation for students who passed MBBS from the same institution) is permissible to a reasonable extent, as held in Jagadish Saran v. Union of India (1980) 2 SCC 768, but residence-based reservation is not. (Paras 7-8) C) Constitutional Law - State Quota - Filling of Seats - Article 14 of the Constitution of India - Since residence-based reservation is impermissible, the State Quota seats (other than permissible institutional preference seats) must be filled purely on the basis of merit in the NEET examination, without any residence or domicile criteria. (Paras 5, 12)
Issue of Consideration
Whether providing for domicile/residence-based reservation in admission to PG Medical Courses within the State Quota is constitutionally valid?
Final Decision
The Supreme Court answered question 1 in the affirmative, holding that residence-based reservation in PG Medical Courses is constitutionally invalid and impermissible. Consequently, questions 2(a) and 2(b) were not answered. For question 3, the Court directed that State Quota seats, other than permissible institutional preference seats, must be filled purely on the basis of merit in the NEET examination. The appeals were dismissed, and the High Court's decision was upheld.
Law Points
- Residence-based reservation in PG Medical Courses is impermissible
- Institutional preference is permissible to a reasonable extent
- Article 14 prohibits discrimination based on residence for higher medical education
- Merit must be the primary criterion for PG medical admissions
