Case Note & Summary
The dispute arose from the admission process for the M.B.B.S. course at the Government Medical College, Srinagar for the academic year 1980-81. The petitioner, Arti Sapru, challenged the admission of several candidates, claiming that the criteria used for selection were discriminatory and unreasonable. The selection was based on merit in a qualifying examination, an objective test, and a viva voce test, with specific percentages allocated to each. The State Government had issued a notification to classify certain villages as socially and educationally backward to rectify regional imbalances in admissions. However, the Supreme Court found this classification arbitrary, lacking sufficient data to support it, and thus invalid under Article 15(4) of the Constitution. The Court noted that the classification included a vast number of villages, leading to an inference that nearly all areas were deemed backward, which was unreasonable. The allocation of 30% of marks to the viva voce examination was also criticized as excessive, especially given the short duration of interviews. The Court emphasized the need for a more balanced approach in future selections. The presence of a government official on the Selection Committee was deemed lawful, and the admissions of candidates who applied late were upheld due to justified circumstances. Ultimately, the Court quashed the admissions based on the invalid classification and directed that those seats be filled based on open merit, while also advising the State Government to consider the circumstances of displaced candidates sympathetically.
Headnote
A) Constitutional Law - Admission Criteria - Classification of Villages - The classification of villages as socially and educationally backward by the State Government was arbitrary and invalid due to lack of intelligible data. The Court held that the classification did not meet the requirements of Article 15(4) of the Constitution, as it was not supported by adequate material (Paras 39-40). B) Examination Procedure - Viva Voce Marks Allocation - The allocation of 30% of total marks to the viva voce examination was deemed unreasonable and arbitrary, necessitating a revision of the marks ratio for future selections (Paras 41D-G). C) Selection Committee Composition - Presence of Government Official - The appointment of a Government official on the Selection Committee was not found to be against the law, as there is no disqualification based on government employment (Paras 44H-45B). D) Admission Process - Late Applications - The admission of certain candidates who applied late was upheld due to the late announcement of qualifying examination results, recognizing their merit (Paras 42G-H).
Issue of Consideration
Whether the classification of villages as socially and educationally backward for medical college admissions was arbitrary and whether the viva voce examination's marks allocation was reasonable.
Final Decision
The Supreme Court quashed the admissions based on the arbitrary classification of villages and directed that the seats be filled based on open merit. The Court advised the State Government to consider the circumstances of displaced candidates sympathetically.
Law Points
- arbitrariness in classification
- viva voce examination marks allocation
- presence of government official in selection committee
- validity of objective test
- reservation criteria
