SC Strikes Down Domicile-Based Reservation in PG Medical Courses

The Supreme Court on Wednesday ruled that domicile-based reservation in postgraduate (PG) medical courses is unconstitutional, as it violates Article 14 of the Constitution.

A three-judge bench comprising Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, and Justice SVN Bhatti in  Tanvi Behl v. Shrey Goel & Ors held that state quota seats for PG medical courses must be filled solely on merit through NEET-PG scores.

Key Observations by the Court in  Tanvi Behl v. Shrey Goel & Ors

• Domicile Quota Permissible Only for MBBS: The Court clarified that residence-based reservations can be allowed only for undergraduate (MBBS) courses, not for specialised PG courses.
• One Nation, One Domicile: The Bench emphasised that there is no separate domicile for different states, reaffirming that all Indians share a single national domicile.
• Educational Rights Across India: The judgement reiterated that the Constitution grants individuals the right to seek admission in educational institutions anywhere in India.

“We are all domiciles in the territory of India. There is nothing like a provincial or state domicile. We have the right to reside, work, and study anywhere in the country,” Justice Dhulia stated while reading the judgement.

• Medical Merit Over Residence Quotas: Given the critical importance of specialised doctors, the Court ruled that residence-based reservations in PG courses would violate the right to equality (Article 14).

Impact of the Judgement

• Existing PG Students Unaffected: The Court clarified that students already enrolled in PG medical courses or those who have graduated under domicile quotas will not be affected.
• State Quota Seats for PG Admissions: From now on, state quota PG seats must be filled solely based on NEET-PG merit.

• Case Title: Tanvi Behl v. Shrey Goel & Ors
• Case No.: C.A. No. 9289/2019
• Bench: Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, Justice SVN Bhatti