In a landmark judgment on Wednesday, the Supreme Court declared domicile-based reservations in postgraduate (PG) medical courses unconstitutional, stating that they violate Article 14 of the Constitution, which guarantees the right to equality. The ruling establishes a significant precedent, mandating that admissions to PG medical courses under state quotas must be based solely on merit, as determined by the National Eligibility cum Entrance Test (NEET).
A three-judge bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti delivered the verdict, emphasizing that state-imposed domicile requirements for PG medical admissions undermine the constitutional principle of equality. “Residence-based reservation in PG medical courses is clearly violative of Article 14 of the Constitution,” the bench stated.
The court underscored that the concept of domicile is unified across India, rejecting the idea of state-specific domiciles. “We are all domiciles in the territory of India. There is nothing like a provincial or state domicile. There is only one domicile. We are all residents of India,” the bench observed. It further highlighted that Article 19 of the Constitution grants every citizen the right to reside, trade, and practice a profession anywhere in the country, including the right to seek admission to educational institutions nationwide.
While the bench acknowledged that domicile-based reservations might be permissible at the undergraduate (MBBS) level, it firmly ruled that such policies cannot be extended to PG medical courses, where specialization and expertise are paramount. “Considering the importance of specialized doctors in PG medical courses, reservation in higher levels on the basis of residence would be violative of Article 14 of the Constitution,” Justice Dhulia stated while reading out the judgment.
The court, however, provided relief to students currently enrolled or those who have already completed their PG medical education under domicile-based reservation schemes. “This judgment will not affect the domicile reservation already granted. Students who are undergoing PG courses and those who have already passed out from such residence categories will not be affected,” the bench clarified.
The ruling came in response to a batch of petitions challenging domicile-based reservations in PG medical admissions at the Government Medical College and Hospital in Chandigarh. In 2019, a two-judge Supreme Court bench had referred the matter to a larger bench after conflicting views emerged over the Punjab and Haryana High Court’s decision to strike down such reservations as unconstitutional.
The three-judge bench’s verdict now brings clarity to the issue, ensuring that PG medical admissions remain merit-based and free from restrictive domicile criteria. The judgment is expected to have far-reaching implications, reinforcing the principle of equal opportunity in higher education and paving the way for a more unified and merit-driven medical education system in India.
The case, Dr. Tanvi Behl (SV) vs. Shrey Goel and Others, had drawn significant attention due to its impact on medical education and the broader debate on reservation policies. With this ruling, the Supreme Court has reaffirmed the importance of meritocracy in specialized fields like medicine, while balancing the interests of students already benefiting from domicile-based reservations.