Case Note & Summary
The dispute arose from the admission process for post-graduate courses in five medical colleges affiliated with the University of Rajasthan. The respondents, who had taken a common competitive examination, were denied admission despite securing higher marks than some successful candidates who benefited from a provision in Ordinance No. 278-E(d)(ii) that granted a 5% mark addition for candidates graduating from the same institution. The respondents challenged this provision, arguing it violated Article 14 of the Constitution, which guarantees equality before the law. The Rajasthan High Court ruled the provision unconstitutional, leading to the appeal by the State of Rajasthan. The Supreme Court upheld the High Court's decision, emphasizing that the additional marks created a significant advantage for candidates from the same college, undermining the merit-based admission process. The court noted that while the provision appeared to offer equal treatment, it resulted in oppressive inequality in practice. The court concluded that the provision was unconstitutional and quashed it, directing that future admissions be conducted without this institutional preference. The court also ensured that students already admitted under the interim order would not be disturbed. The judgment reinforced the principle of equality in educational admissions, highlighting the need for a fair and merit-based selection process.
Headnote
A) Constitutional Law - Equality Doctrine - Violation of Article 14 - Constitution of India, 1950, Article 14 - The provision granting 5% additional marks to candidates who graduated from the same college for post-graduate admissions was held unconstitutional as it created an unfair advantage, undermining the merit-based selection process. The court found that this institutional preference led to significant inequality among candidates, violating the equality doctrine. Held that the provision was unconstitutional (Paras 495-502).
Issue of Consideration
Whether the provision of Ordinance No. 278-E(d)(ii) of the University of Rajasthan, which grants additional marks to candidates based on their college of graduation, violates the equality principle enshrined in Article 14 of the Constitution.
Final Decision
The Supreme Court dismissed the appeals, declaring Ordinance 278-E(d)(ii) unconstitutional and quashing it. The court ordered that future admissions to post-graduate courses in all medical colleges in Rajasthan be conducted without the provisions of the ordinance, ensuring adherence to the equality doctrine.
Law Points
- Constitutional validity
- Article 14
- equality doctrine
- institutional preference
- medical college admissions
