Case Note & Summary
The dispute arose from the admission rules for post-graduate medical courses in four medical colleges in Bombay, three run by the Municipal Corporation and one by the State Government. The Municipal Corporation's Rule 4A and the State's Rule 5 provided for college-wise institutional preferences, favoring candidates who graduated from the same college for admission to post-graduate courses, regardless of their merit compared to candidates from other colleges. This led to a challenge in the High Court, which found the rules discriminatory and violative of Article 14 of the Constitution, resulting in their invalidation. The Supreme Court dismissed the appeals against this decision, affirming that any preference other than merit is unreasonable and discriminatory. The Court directed that the admissions already made under the impugned rules should not be disturbed but mandated the appellants to frame new rules for future admissions in compliance with constitutional provisions. The Court clarified that the preference based on college affiliation does not hold merit, especially when the same university governs all colleges involved, and emphasized the need for equality in educational opportunities (Paras 920-934).
Headnote
A) Constitutional Law - Discriminatory Admission Rules - College-wise institutional preference for medical college admissions - Constitution of India, 1950, Article 14 - The Supreme Court upheld the High Court's decision to strike down college-wise institutional preferences as discriminatory, emphasizing that merit must be the sole criterion for admissions in educational institutions. The Court noted that such preferences violate the equality clause as they exclude meritorious candidates based on their college of graduation (Paras 920-933).
Issue of Consideration
Whether the college-wise institutional preference for admission to post-graduate medical courses violates Article 14 of the Constitution.
Final Decision
The Supreme Court dismissed the appeals, affirming the High Court's ruling that college-wise institutional preferences are discriminatory and violate Article 14 of the Constitution. The Court directed that admissions already made under the impugned rules should not be disturbed and mandated the appellants to frame new rules for future admissions consistent with constitutional provisions.
Law Points
- Constitutional validity
- Article 14
- educational institutions
- merit-based admission
- discriminatory classification
