The Supreme Court on Wednesday ruled that reservation based on domicile or residence for admissions to postgraduate medical courses under the State Quota violates the right to equality under Article 14 of the Indian Constitution in Tanvi Behl v. Shreya Goyal.
A Bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti emphasized that admissions must be solely based on merit. The Court observed, “We are all domiciled in India, and there is no concept of provincial domicile. This entitles individuals to pursue trade and education across the country. While reservation based on residence may be permissible for MBBS admissions in some cases, extending it to higher education levels violates Article 14.â€
However, the Court clarified that its ruling would not affect domicile-based reservations that have already been granted.
This decision stemmed from a 2019 reference by a two-judge Bench, which had posed key constitutional questions, including:
1. Whether domicile-based reservation in PG medical admissions under the State Quota is unconstitutional.
2. If such reservation is permissible, to what extent and in what manner should it be provided?
3. If it is impermissible, how should State Quota seats, apart from institutional preference seats, be allocated?
The case arose from appeals against a Punjab and Haryana High Court ruling, which had invalidated domicile-based reservation provisions in the Government Medical College and Hospital, Chandigarh’s prospectus under the UT Chandigarh Pool. Senior Advocate Nidhesh Gupta, appearing for private respondents, argued that such reservations were unconstitutional, aligning with the High Court’s decision.
