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Dr. Kriti Lakhina and Others v. State of Karnataka and Others

Writ Petition (Civil) · 2018 INSC 302Decided 4 Apr 2018
Writ Petition (Civil) No. 204 of 2018
Justice Arun Mishra · Justice Uday Umesh Lalit

Background

44 doctors who completed their MBBS/BDS courses in Karnataka and cleared the NEET-PG 2018 exam with good merit challenged Clause 4.1 of Karnataka's 2018 Information Bulletin for postgraduate medical/dental admissions. That clause required a candidate to be of "Karnataka origin" (essentially a domicile-type requirement going beyond merely having studied in Karnataka) to compete even for the state's own government-quota seats, which effectively shut out meritorious students who had studied in Karnataka but did not separately satisfy the origin test.

Decision Breakdown

The Court held that this was squarely covered by its own earlier decision in Vishal Goyal v. State of Karnataka (2014), which had struck down an identically worded clause in the 2014 Bulletin as unconstitutional. Relying on a long line of precedent (including Dr. Pradeep Jain v. Union of India) holding that reservation in postgraduate medical admissions based on residence/domicile violates Article 14's guarantee of equality, since merit must be the dominant criterion at that advanced level of specialisation, the Court declared Clause 4.1 invalid to the extent it disqualified petitioners and similarly-placed candidates who had completed their MBBS/BDS from Karnataka colleges from competing for government-quota postgraduate seats. It allowed the writ petition and directed the State to amend the Bulletin and complete the admission process accordingly.

Lesson Learnt

A state cannot use a "domicile" or "origin" requirement to deny meritorious candidates a fair shot at postgraduate medical admission merely because they do not also satisfy additional residence criteria beyond having studied in that state: reservation/preference schemes in higher medical education must yield to the constitutional guarantee of equality and merit.

Official source (sci.gov.in)View Judgment (PDF)

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