Supreme Court Strikes Down Discriminatory Admission Guidelines for Medical Colleges — Upholds Combined Merit List Principle.

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Case Note & Summary

The case involved a challenge to the guidelines issued by the University of Lucknow regarding admissions to Post-Graduate Medical Courses in Uttar Pradesh. The petitioners contended that the college-wise merit list prepared from institutional candidates was discriminatory and violated Article 14 of the Constitution. They argued that in most states, a combined merit list was prepared after a common entrance examination, allowing for fairer admissions. The Supreme Court, referencing previous judgments, found that the college-wise preference was arbitrary and struck it down, directing the State to create a combined merit list for all candidates. The Court emphasized that no vested rights existed for candidates based on the impugned guidelines, as no admissions had yet been made. The ruling mandated that the State Government issue a notification for admissions based on the combined merit list and allow candidates to express their preferences for specialities. The decision reinforced the principle that merit should not be sacrificed for convenience, ensuring that all eligible candidates had equal opportunities regardless of their college of origin.

Headnote

A) Constitutional Law - Discrimination in Admission Process - College-wise Merit List - Violation of Article 14 - Constitution of India, 1950, Article 14 - The Supreme Court struck down the provision for preparing a college-wise merit list for admissions to Post-Graduate Medical Courses, directing the State to prepare a combined merit list for all colleges, as the existing rule was found to be arbitrary and discriminatory. Held that merit must prevail over institutional preference (Paras 364-370).

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Issue of Consideration

Whether the preparation of a college-wise merit list for admissions to Post-Graduate Medical Courses is discriminatory and violative of Article 14 of the Constitution.

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Final Decision

The Supreme Court struck down the college-wise merit list provision and directed the State to prepare a combined merit list for admissions to Post-Graduate Medical Courses, ensuring equal opportunity for all candidates.

Law Points

  • Discrimination
  • Article 14
  • Merit List
  • Combined Entrance Examination
  • Institutional Preference
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Case Details

1992 LawText (SC) (05) 26

Writ Petition (C) No.964 of 1991

1992-05-15

KASLIWAL, N.M., SHARMA, L.M.

1992 AIR 1475, 1992 SCR (3) 363, 1992 SCC (3) 232, JT 1992 (3) 508, 1992 SCALE (1) 1120

Gobind Mukhoty, D.K. Garg, R.C. Kaushik, A.S. Nambiar, R.B. Misra, L.R. Singh, S.K. Agnihotri, J.R. Das, D.K. Sinha, G. Prabhakar, Smt. Shanta Vasudevan, P.K. Manohar, G.K. Bansal, B.B. Singh, T.T. Kunikannan, Ms. Kamini Jaiswal, Pramod Swarup

P.K. Goel and Ors.

U.P. Medical Council and Ors.

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Nature of Litigation

Challenge to admission guidelines for Post-Graduate Medical Courses.

Remedy Sought

Petitioners sought to strike down the college-wise merit list and implement a combined merit list.

Filing Reason

Alleged discrimination and violation of Article 14 in the admission process.

Previous Decisions

Previous rulings had established the principle of a combined merit list for admissions.

Issues

Whether the college-wise merit list is discriminatory. Whether the existing admission guidelines violate Article 14.

Submissions/Arguments

Petitioners argued that the college-wise merit list was arbitrary and discriminatory. Respondents contended that candidates had a right based on the existing guidelines.

Ratio Decidendi

The Court held that merit must prevail over institutional preferences in admissions, reinforcing the principle of equality under Article 14.

Judgment Excerpts

Rule (G)(ii) laying down the provision for preparing a merit list for each college out of the institutional candidates of that college, is struck down. There cannot be any right vested in the candidates in seeking admission in a particular college. Merit as the basis for selection in the speciality in a Post-Graduate course cannot be sacrificed against convenience.

Procedural History

The petition was filed under Article 32 of the Constitution challenging the guidelines for the Post-Graduate Medical Entrance Examination conducted by the University of Lucknow.

Acts & Sections

  • Constitution of India: Article 14
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