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Education LawSupreme Court of India

Rajdeep Ghosh v. State of Assam & Ors.

Writ Petition (Civil) · 2018 INSC 718Decided 17 Aug 2018
Writ Petition (Civil) No. 766 of 2018
Justice Arun Mishra · Justice S. Abdul Nazeer

Background

A group of Assam residents who had completed Class XI and XII outside Assam challenged Rule 3(1)(c) of the Medical Colleges and Dental Colleges of Assam (Admission) Rules, 2017, which required candidates to study Class VII to XII within Assam to be eligible for State-quota MBBS/BDS seats. They argued the rule was arbitrary and violated Article 14, since they were otherwise permanent residents of Assam and had cleared NEET. The State defended the rule as necessary to ensure that doctors trained with State resources actually serve Assam's population, particularly its underserved regions.

Decision Breakdown

The Supreme Court dismissed all the writ petitions and the tagged SLP, upholding Rule 3(1)(c) as constitutional. Surveying a long line of precedent (D.P. Joshi, Pradeep Jain, Saurabh Chaudri, and others), the Court held that residence- and education-based preferences for basic MBBS/BDS admission (as opposed to postgraduate/super-specialty admission) are permissible under Article 14 because they have a rational nexus to the State's legitimate goal of retaining doctors to serve its own population. The Court found the rule's exceptions (for children of government employees posted outside the State) were reasonably tailored, and declined to extend similar relief to children of private-sector employees or those who left Assam voluntarily for "better coaching," since there was no data showing such facilities were unavailable in Assam.

Lesson Learnt

A state can lawfully condition reserved "state quota" professional-course seats on having actually studied within the state, as a rational way to ensure publicly-funded medical education benefits the state's own residents: this is settled law for basic MBBS/BDS courses even though a stricter standard applies at the postgraduate level.

Rajdeep Ghosh v. State of Assam & Ors. – Legal Case Shots | LegalAware