Supreme Court Upholds Limited Reservation Based on State Residence for Medical College Admissions, Emphasizing National Unity and Meritocracy

Court Declares Wholesale Reservation on Domicile Grounds Unconstitutional; Sets 70% Cap on State-Based Quotas for MBBS Admissions and Restricts Postgraduate Reservations

In a landmark judgment delivered on June 22, 1984, the Supreme Court of India addressed a crucial constitutional issue concerning the validity of domicile or residence-based reservations for admissions to medical colleges across the country. The case, arising from a cluster of writ petitions and civil appeals including prominent litigants such as Dr. Pradeep Jain and Miss Reita Nirankari, examined whether states could impose residence requirements or reservations that give preferential treatment to candidates domiciled or residing within the state for admission to undergraduate and postgraduate medical courses.

The Supreme Court, comprising Justices P.N. Bhagwati, Amarendra Nath Sen, and Ranganath Misra, delivered a unanimous verdict that balances the competing interests of state autonomy in educational policies and the constitutional mandate for equality and national integration.

Key Findings and Directions:

1. Concept of Domicile and Residence:

The Court clarified that the legal concept of domicile, as understood internationally, applies only to the country as a whole, not to individual states within India. The Constitution recognizes only one domicile — domicile in the territory of India. Therefore, the use of "domicile" by states in admission rules is a misnomer, often used colloquially to mean residence. The Court cautioned states against using the term “domicile” in a way that could foster separatist tendencies and undermine national unity.

2. Article 16(2) and Residence-Based Discrimination:

While Article 16(2) of the Constitution prohibits discrimination in state employment on grounds including residence, this provision does not apply to admissions to educational institutions. Hence, residence requirements for medical college admissions are not invalid per se under Article 16(2). The challenge to residence-based admissions must therefore be tested under the broader equality clause of Article 14.

3. Reservation Based on Residence Validity:

The Court acknowledged that states have a legitimate interest in encouraging medical education among residents likely to serve the state's population. Past precedents, such as *D.P. Joshi v. State of Madhya Bharat* and *N. Vasundhara v. State of Mysore*, which upheld residence-based reservations, were reiterated. The rationale is that students who have resided in the state for a specified period are more likely to settle there and address local medical needs.

4. Limits on Extent of Reservation:

While residence-based reservation is permissible to promote social justice and equality of opportunity, the Court held that wholesale reservation exceeding a reasonable limit violates Article 14. It fixed an outer limit of 70% for such reservations in undergraduate (MBBS and BDS) courses. This ensures that at least 30% of seats remain open for all-India candidates, selected purely on merit.

5. Postgraduate Admissions:

For postgraduate medical courses (M.D., M.S., M.D.S.), the Court ruled that merit should be the paramount criterion, and residence-based reservations are not desirable. However, institutional preference — giving some advantage to candidates who completed their undergraduate studies at the same university — may be allowed but must not exceed 50% of the seats. For super-specialty courses, no reservations whatsoever should be permitted, and admissions must be fully merit-based on an all-India basis.

6. Institutional Preference and Regional Backwardness:

The Court recognized institutional preference for candidates affiliated with the university as reasonable and constitutionally valid. It also acknowledged that reservations aimed at correcting regional backwardness within a state might be justified to promote equality in a broader social context.

7. National Unity and Equality:

The judgment stressed the constitutional vision of India as one nation with one citizenship. It condemned parochial and regional "sons of the soil" policies that threaten national unity. The Court invoked the Preamble and Articles 14, 15, 19(1), and 301, emphasizing free movement and equality of opportunity for all citizens irrespective of their state of residence.

8. Role of Indian Medical and Dental Councils:

The Court directed the Indian Medical Council and Indian Dental Council to review and monitor the extent of reservations periodically and recommended a gradual reduction of state-based reservations over time to move towards an ideal of all-India merit-based admissions.

Implications of the Judgment:

This judgment marks a significant step toward harmonizing state interests and national constitutional values in medical education. It permits states to maintain reasonable residence-based reservations to ensure equitable development and address local health needs, but it firmly prohibits excessive and blanket reservation policies that undermine merit and national integration. The ruling also sets a clear precedent for other technical and professional educational institutions.

The Court’s emphasis on meritocracy, social justice, and national unity serves as a guiding principle for framing admission policies in higher education, balancing the need to uplift disadvantaged regions and communities without compromising excellence and equality.

Background:

The case arose amid increasing demands by states to reserve seats for residents in their medical colleges, justified as a means to serve local populations and address disparities in educational opportunities and medical services. Opponents of such reservations argued that they violated constitutional guarantees of equality and freedom of movement.

The Supreme Court undertook a detailed examination of constitutional provisions, historical context, and prior judgments, ultimately steering a middle path that respects both state concerns and national constitutional ideals.

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Statutory provisions

Article 1, Article 5, Article 14, Article 15, Article 16(2), Article 16(3), Article 19(1), Article 301 of the Constitution of India

Pradeep Jain, Dr. v. Union of India, (SC) : Law Finder Doc Id # 90855