Yatinkumar Jasubhai Patel & Ors. v. State of Gujarat & Ors.
Background
Several medical graduates challenged the practice of "Institutional Preference" in admission to Post Graduate Medical Courses, under which universities like Gujarat University, Delhi University and Guru Gobind Singh Indraprastha University gave preference to their own graduates for a share of postgraduate seats. The challengers argued that after the introduction of the National Eligibility Entrance Test (NEET), which was meant to ensure admissions purely on merit through a single centralised exam, this kind of institutional preference should no longer be allowed. A two-judge bench had earlier referred the matter to a larger bench given its wide-ranging importance across universities.
Decision Breakdown
The Supreme Court held that institutional preference in postgraduate medical admissions, capped at 50% of open seats, had been consistently approved by the Court since 1971 through a series of decisions including a Constitution Bench ruling, and that the introduction of NEET did not disturb this settled position. The Court reasoned that NEET's purpose was only to ensure a single, centralised, merit-based entrance examination rather than separate university-level tests: it did not abolish the concept of giving some preference to a university's own graduates for its own postgraduate seats, as long as admissions within that preference quota are still based on NEET merit. The appeals and connected writ petitions challenging institutional preference were accordingly dismissed with no order as to costs.
Lesson Learnt
Introducing a common, centralised entrance exam like NEET standardises how merit is measured, but it does not automatically do away with other settled admission policies, such as giving limited preference to a university's own graduates, unless a law or regulation specifically says so.