Merit vs. Reservation: The Battle Over Medical Admissions

A Clash Over Equal Opportunity

In a significant legal showdown, whether states can provide residence-based reservations for postgraduate (PG) medical courses has sparked intense debate. The dispute revolves around whether such reservations align with constitutional principles or violate the right to equality. The Supreme Court’s recent judgment has once again reaffirmed that when it comes to higher education, particularly specialized courses, merit must take precedence over domicile-based preferences.
The Crux of the Matter
At the heart of the dispute lies a medical college that had implemented a reservation policy favoring candidates who either completed their undergraduate medical studies at the institution or had a long-term residence in the Union Territory where the college is located. Of the 64 postgraduate seats available under the state quota, half were reserved for students who had pursued their MBBS at the institution. In contrast, the remaining half were allocated to those fulfilling certain residence criteria.
Several aspiring medical students challenged this policy, arguing that it effectively barred deserving candidates from other regions despite their superior performance in national-level entrance exams. They contended that the policy contravened established legal precedents that have consistently ruled against domicile-based reservations at the PG level.

The Legal Debate: Perspectives from Both Sides

The petitioners, students who were denied admission under the impugned policy, relied heavily on three landmark Supreme Court rulings: Jagadish Saran v. Union of India (1980), Dr. Pradeep Jain v. Union of India (1984), and Saurabh Chaudri v. Union of India (2003). These cases collectively held that while institutional preference may be permissible to a reasonable extent, residence-based reservations in postgraduate medical courses violate Article 14 of the Constitution, which guarantees equality before the law.
Their argument was straightforward: merit must be the sole criterion for selection in specialized medical fields, as reservations based on residence arbitrarily exclude highly qualified candidates. They highlighted that such a policy fails to maintain a fair balance between local considerations and the broader need for medical excellence.

State’s Defense:

The state and the institution defended the policy by arguing that the reservation was necessary to ensure adequate medical professionals serve the local population. They contended that students who reside in the region or have studied at the institution are more likely to continue serving in local healthcare institutions, thereby addressing the shortage of specialists.
The state further asserted that education is a matter on the concurrent list, allowing them the flexibility to design policies that cater to regional needs. They also emphasized that Article 15 of the Constitution does not explicitly prohibit residence-based reservations in education.

The High Court Ruling: Striking Down the Policy

The Punjab and Haryana High Court ruled in favor of the petitioners, declaring the reservation system unconstitutional. It held that residence-based reservations in PG medical courses violated Article 14 by discriminating against non-resident candidates purely on geographical grounds. The court directed that admissions should be based strictly on merit as per NEET-PG rankings.
The judgment emphasized that the eligibility criteria were overly broad and irrational, allowing even those who had merely studied in Chandigarh for five years or owned property to qualify under the reservation scheme.
The Supreme Court’s Verdict: A Resounding Affirmation of Meritocracy
The matter reached the Supreme Court, where a larger bench examined whether domicile-based reservations in PG medical courses could withstand constitutional scrutiny. The Court, upholding the High Court’s decision, ruled that such reservations are impermissible and violate Article 14.

Key Takeaways from the Judgment:

The Court reaffirmed that merit should be the primary criterion for PG medical admissions. Unlike undergraduate medical courses, where some degree of domicile-based preference may be allowed, PG courses demand a stricter merit-based selection process.
The judgment reiterated that under the Indian legal framework, there is no concept of state-specific domicile. Every citizen is domiciled in India as a whole, and creating provincial domicile categories contradicts constitutional principles.
The Court heavily relied on prior judgments, particularly Dr. Pradeep Jain and Saurabh Chaudri, which held that residence-based reservations in higher education are unconstitutional.
While Article 15 prohibits discrimination based on place of birth but is silent on residence, the Court emphasized that reservations must still pass the reasonableness test under Article 14. Moreover, Article 16(3) permits Parliament—not states—to impose residence-based restrictions, but only in matters of employment, not education.

Conclusion: A Win for Meritocracy

By striking down domicile-based reservations in PG medical courses, the Supreme Court has upheld the sanctity of merit in higher education. This decision ensures that aspiring medical professionals, irrespective of their state of origin, compete on an equal footing, ultimately enhancing the quality of medical expertise in the country. As India strives for excellence in healthcare, this judgment paves the way for a more inclusive and merit-driven medical education system.