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Justice V. Eswaraiah (Retd.) v. Union of India

Writ Petition (Civil) · 2025 INSC 342Decided 25 Feb 2025
Writ Petition (Civil) No. 452 of 2019
Justice B.R. Gavai · Justice Augustine George Masih

Background

A retired High Court judge, appearing in person on behalf of an organisation called the All India Backward Classes Federation, filed a public interest petition challenging certain admission rules of Andhra Pradesh and Telangana governing postgraduate medical courses. His core grievance was that Telangana's rules (unlike Andhra Pradesh's, which had already been amended) did not properly treat "Meritorious Reserved Candidates", reserved-category candidates who qualify on their own merit, as open-category candidates, which he argued unfairly reduced the number of seats effectively available to other reserved-category candidates.

Decision Breakdown

The Court noted that the settled legal position on this issue, as laid down in cases like Indra Sawhney and R.K. Sabharwal, was already clear for undergraduate (MBBS) admissions, but that postgraduate admissions involved added complexity around candidates moving between specialties and categories. The Court held that such a complex, fact-specific question about how reservation percentages interact with individual candidates' choices could not be resolved in the abstract through a public interest litigation, especially without hearing the actual affected candidates who might be adversely impacted by any ruling. It therefore disposed of the petition without deciding the substantive question, leaving it open for High Courts to decide individual cases raising this issue on their own specific facts as they arise.

Lesson Learnt

Courts will decline to lay down sweeping policy rules on complex reservation questions through a public interest petition when doing so would affect specific individuals who are not before the court: such disputes are better resolved case-by-case, with all affected parties actually heard.

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

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