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Ramnaresh @ Rinku Kushwah and Others vs. State of Madhya Pradesh and Others

Not available · 2024 INSC 611Decided 20 Aug 2024
Not available
Justice B.R. Gavai · Justice K.V. Viswanathan

Background

Madhya Pradesh reserves a "Government School" (GS) quota within MBBS admissions, and within that quota further sub-divides seats by caste/category (UR-GS, SC-GS, OBC-GS, etc.) : a form of horizontal reservation layered on vertical reservation. Several NEET-2023 candidates from reserved categories (SC/OBC/EWS) scored well above the cut-off for the unreserved (UR-GS) seats but were still placed only in their own category's GS seats, while candidates with far lower marks got UR-GS seats. When the unfilled UR-GS seats (77 of 89) were released to the general open pool instead of going to these meritorious reserved candidates, the candidates challenged this before the Madhya Pradesh High Court, which dismissed their petitions; they then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that the State's approach of rigidly compartmentalizing each category within the horizontal GS quota was legally unsustainable, relying on its earlier decisions in Saurav Yadav v. State of U.P. and Sadhana Singh Dangi v. Pinki Asati. The settled principle is that a reserved-category candidate who qualifies for the "open"/general slot of a horizontal quota purely on their own merit must be placed in that open slot, and this does not count against their vertical reservation quota: reservation is meant to ensure representation, not to act as a rigid ceiling on a meritorious candidate's placement. Since the appellants clearly outscored the cut-off applied for UR-GS seats, they were wrongly denied those seats. As the 2023-24 admission cycle was already complete, the Court could not simply insert them into that year's cohort, so, following its ruling in S. Krishna Sradha v. State of A.P. on molding relief for wrongly denied medical admissions. It directed the State to admit the appellants into the UR-GS quota for the next academic session (2024-25), using the 7 seats it had already ordered kept vacant pending this judgment.

Lesson Learnt

Reservation categories, whether vertical (caste-based) or horizontal (e.g., government-school quota), cannot be used to artificially cap a meritorious candidate's placement. If a reserved-category candidate qualifies for the open/general slot on merit alone, authorities must place them there rather than confining them to their own category's seats.

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

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