Supreme Court Upholds Admission Process for PG Medical Courses — Invalidates Domicile-Based Reservation. The Court ruled that domicile/residence-based reservations are unconstitutional and violate the principle of equality under Article 14.

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Case Note & Summary

The dispute arose from the High Court's judgment invalidating domicile/residence-based reservations for admissions to PG Medical Courses at the Government Medical College and Hospital, Chandigarh. The appellant, Dr. Tanvi Behl, along with other candidates, challenged the High Court's order which struck down the provisions in the prospectus that allowed for such reservations. The High Court found that the criteria for domicile-based reservations were arbitrary and violated Article 14 of the Constitution, as they favored candidates based on residence rather than merit. The appellants argued that the High Court erred in its interpretation and that domicile-based reservations were permissible under the law. They contended that the Supreme Court's previous rulings did not categorically disapprove such reservations. The Supreme Court, however, upheld the High Court's decision, reiterating that admissions to PG Medical Courses should be merit-based and that the criteria set forth in the prospectus were invalid. The Court directed that admissions should be conducted based on merit obtained in the National Eligibility-Cum-Entrance Test (NEET). The final decision emphasized the need for fairness in the admission process and the importance of merit over arbitrary criteria.

Headnote

A) Constitutional Law - Domicile/Residence-Based Reservation - Invalidity of Domicile-Based Reservation - Constitution of India, Article 14 - The High Court struck down domicile/residence-based reservation for PG Medical Courses, holding it arbitrary and violative of the right to equality. The Supreme Court upheld this decision, emphasizing that admissions must be based on merit, not residence. Held that such reservations are unsustainable in law (Paras 10.3, 11.1).

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Issue of Consideration

Whether domicile/residence-based reservation for admission to PG Medical Courses is constitutionally valid.

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Final Decision

The Supreme Court upheld the High Court's decision, invalidating the domicile/residence-based reservation for PG Medical Courses and directing that admissions be based solely on merit as determined by NEET scores.

Law Points

  • Constitutional validity
  • domicile/residence-based reservation
  • merit-based admission
  • institutional preference
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Case Details

2019 LawText (SC) (12) 162

Civil Appeal No. 9289 of 2019

2019-04-23

Dinesh Maheshwari

Dr. Tanvi Behl

Shrey Goel & Ors.

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Nature of Litigation

Challenge to the validity of domicile/residence-based reservation for PG Medical Courses admissions.

Remedy Sought

Appellants sought to retain their admissions based on domicile/residence-based criteria.

Filing Reason

The High Court invalidated the domicile/residence-based reservation provisions.

Previous Decisions

The High Court had previously ruled against domicile-based reservations in the context of PG Medical admissions.

Issues

Is domicile/residence-based reservation for PG Medical Courses constitutionally valid? What is the appropriate basis for admissions to PG Medical Courses?

Submissions/Arguments

Appellants argued that domicile-based reservations were permissible and not unconstitutional. Respondents contended that such reservations violate Article 14 and should not be allowed.

Ratio Decidendi

The Court emphasized that admissions to PG Medical Courses must be based on merit, rejecting domicile/residence-based reservations as arbitrary and unconstitutional under Article 14.

Judgment Excerpts

The High Court struck down domicile/residence-based reservation for PG Medical Courses, holding it arbitrary and violative of the right to equality. Held that such reservations are unsustainable in law.

Procedural History

The appeals arose from a common judgment of the High Court of Punjab and Haryana, which invalidated domicile/residence-based reservations in the prospectus for PG Medical Courses.

Acts & Sections

  • Constitution of India: Article 14
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