Domicile-Based Reservation in Medical PG Seats: SC Struck Down
The Supreme Court of India recently struck down the practice of domicile-based reservation in postgraduate medical seats, declaring it unconstitutional and violative of the principles of equality and meritocracy under Articles 14 and 15 of the Constitution. This decision has significant implications for medical education, state autonomy, and the allocation of professional opportunities.
Domicile-based reservation allowed candidates from a particular state to claim preferential treatment in state-run medical colleges’ PG courses, often to ensure local representation and address regional healthcare needs. States argued that such reservations were necessary to retain medical professionals locally and improve state health infrastructure, linking it to Article 16(4) — reservation in public employment for backward classes.
The Supreme Court, however, emphasized that higher education and professional courses require a uniform merit-based system. It held that reservation solely on the basis of domicile does not satisfy constitutional tests of reasonable classification because it:
- Discriminates against equally or more meritorious candidates from other states.
- Does not consider social and educational backwardness, which is the intended focus of affirmative action under Articles 15 and 16.
- Encroaches upon the fundamental right to equality, as domicile alone cannot justify differential treatment in competitive exams or professional courses.
The Court also clarified that while states have the power to plan and implement local development schemes, such policies cannot infringe upon meritocracy or fundamental rights guaranteed under the Constitution. It further stressed that healthcare access and regional representation can be addressed through policy measures, such as service bonds or incentives for doctors to serve in specific regions, without compromising the merit-based selection process.
The judgment reinforces the principle that educational reservations must be based on socially and educationally backward classes or other constitutionally permissible criteria, not mere geographical origin. It aligns with previous rulings emphasizing equality, non-arbitrariness, and the primacy of merit in professional and competitive contexts.
In conclusion, the Supreme Court’s decision striking down domicile-based reservation in medical PG seats ensures that selection remains fair, transparent, and merit-driven, while suggesting that state objectives like local healthcare improvement should be pursued through incentive-based schemes or service obligations. This judgment strengthens the constitutional framework of equality, non-discrimination, and rational classification in professional education.