Dr. Tanvi Behl v. Shrey Goel
Background
The case concerned admissions to PG Medical Courses at Government Medical College, Chandigarh, where a portion of "State quota" seats were reserved specifically for residents/domiciles of the Union Territory of Chandigarh, on top of institutional-preference seats. Students who felt disadvantaged by this residence-based carve-out challenged its constitutional validity, arguing that all PG seats should be filled purely on NEET merit. A three-judge bench was called on to resolve whether domicile-based reservation at the postgraduate (as opposed to undergraduate/MBBS) level is permissible under the Constitution.
Decision Breakdown
The Court held that residence/domicile-based reservation in postgraduate medical admissions is unconstitutional and violates Article 14 (the right to equality), because at the specialist/postgraduate level the country needs the most qualified doctors regardless of which state they come from, and reserving seats by residence unfairly disadvantages equally or more meritorious students from other states. The Court distinguished this from MBBS (undergraduate) admissions, where a limited degree of residence-based preference has previously been upheld for different policy reasons. However, to protect students who had already secured admission and completed or were undergoing their PG courses under the old residence-based scheme (including the appellants themselves, due to an earlier interim order), the Court made its ruling prospective only and did not disturb their already-granted admissions.
Lesson Learnt
Reservation policies that make sense at one level of education (like undergraduate medical admissions) don't automatically carry over to another level (like postgraduate specialisation). Courts will strike down residence-based quotas in PG medical admissions as discriminatory, even while protecting students who already relied on the old rule in good faith.