Case Note & Summary
The case involved a writ petition filed by two petitioners seeking to quash the alteration of Petitioner No. 2's caste status from Scheduled Tribe (ST) to Unreserved (UR) by Respondent No. 4, which affected his admission to the MBBS course. Petitioner No. 1, the father of Petitioner No. 2, had been residing in the Union Territory of Dadra and Nagar Haveli since 1996, while Petitioner No. 2 was born there and had completed his education in the same territory, consistently recognized as an ST. The petitioners argued that the alteration was illegal and sought to have Petitioner No. 2's name reinstated in the ST Merit List. The Court noted that Petitioner No. 2 had been issued a Caste Certificate confirming his ST status and a Domicile Certificate affirming his residency. The Court found that the alteration of status was arbitrary and violated Article 14 of the Constitution, which mandates fairness in state action. The Court referenced previous judgments that established the principle that residency, rather than origin, determines eligibility for reservation benefits. Ultimately, the Court quashed the alteration and directed the inclusion of Petitioner No. 2 in the ST Merit List, ordering the allotment of an ST seat for the MBBS course for the academic year 2026-2027.
Headnote
A) Constitutional Law - Reservation and Admission - Status Change from ST to UR - Article 14 of the Constitution of India - The Court held that the alteration of Petitioner No. 2's status from ST to UR was arbitrary and unjustified, as he was a permanent resident of the Union Territory and had been recognized as ST throughout his education. The Court directed the inclusion of Petitioner No. 2's name in the ST Merit List and the allotment of an ST seat for the MBBS Course (Paras 41-41).
Issue of Consideration
Whether the alteration of Petitioner No. 2's status from Scheduled Tribe to Unreserved was justified and whether he is entitled to admission under the ST category.
Final Decision
The Court allowed the writ petition, quashing the alteration of Petitioner No. 2's status from ST to UR, directing the inclusion of his name in the ST Merit List, and ordering the allotment of one ST seat for the MBBS Course for the academic year 2026-2027.
Law Points
- Reservation based on residence
- Caste Certificate validity
- Educational admissions
- Article 14 of the Constitution
- Presidential Notifications
