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The Supreme Court recently ruled that domicile-based reservations for postgraduate (PG) medical courses are unconstitutional, violating Article 14 of the Constitution. This landmark decision mandates that PG medical admissions, under state quotas, must be based purely on merit determined by the National Eligibility cum Entrance Test (NEET). A three-judge bench, consisting of Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti, stated that such state-imposed domicile requirements contravene the constitutional principle of equality.
The bench clarified that residency-based reservations in PG medical courses were incompatible with the constitutional guarantees of equality and could not be upheld. "We are all domiciles of India; there is no concept of state-specific domicile," the bench emphasized, asserting that under Article 19 of the Constitution, every citizen has the right to reside, work, and pursue education anywhere in India. The court also highlighted that the Constitution guarantees the right to admission in educational institutions across the country and that domicile-based restrictions for PG medical programs undermined this core principle. Although the court acknowledged the possibility of some domicile-based reservations in undergraduate (MBBS) admissions, it firmly stated that such measures would be unconstitutional for PG medical programs, where specialisation and expertise are paramount.
Justice Dhulia, reading the judgment, underscored that reservation based on domicile in advanced medical courses violated Article 14 due to the importance of skilled professionals in the medical field. The court also made it clear that the ruling would not affect students already enrolled or those who had completed PG medical education under these domicile-based schemes. "Students currently undergoing PG courses or those who have already graduated under domicile reservations will not be impacted by this judgment," the bench stated.
In 2019, the issue was raised when appeals were filed against a Punjab and Haryana High Court decision that had deemed domicile reservations in PG medical admissions unconstitutional. Recognizing the significance of the case, particularly for Chandigarh, which has only one medical college, the Supreme Court referred the matter to a larger bench. The three-judge bench’s recent decision provides clarity, ensuring that PG medical admissions are merit-based and that no state can impose restrictive domicile criteria moving forward.
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