The ruling striking down domicile-based reservations in post-graduate medical admission overlooks the functional realities of public health governance
struck down domicile-based reservations in post-graduate medical
The recent Supreme Court judgment, in Dr. Tanvi Behl vs Shrey Goyal (2025), which struck down domicile-based reservations in post-graduate medical admissions in the respective medical colleges in States, marks a significant shift in India’s medical education policy.
The ruling, holding that such reservations violate Article 14 of the Constitution, dismantles a mechanism that States have long relied upon to ensure a stable medical workforce suited to public health needs.
Domicile quotas in State health planning
सरकार पैसा क्यों ख़र्च करती है ?
Domicile-based reservations in post-graduate medical courses serve a crucial function in aligning State investment in medical education with health-care personnel retention.
States allocate substantial resources to train medical students, expecting that these graduates will contribute to the local health-care system.
डोमिसाइल कोटा प्रदान करने से फायदा ?
Given chronic specialist shortages, domicile quotas ensure a predictable supply of doctors familiar with the State’s health-care landscape.
The Court’s reliance on Pradeep Jain vs Union of India (1984)
to eliminate domicile-based post-graduate reservations overlooks the essential distinction between undergraduate and post-graduate education.
राज्य को किस चीज़ की पूर्ति करते हैं छात्र
Unlike MBBS programmes, where students gain foundational knowledge, post-graduate courses are the primary channel through which States replenish/ full their specialist workforce. Removing domicile quotas disrupts this pipeline, making States becoming increasingly reliant on external recruitment — a process fraught with unpredictability and inefficiencies.
जजमेंट से शायद राज्य अब उतना ख़र्च न करें मेडिकल शिक्षा में
By striking down domicile quotas, the judgment weakens the incentive for States to invest in medical education.
A well-functioning system of competitive federalism encourages States to develop robust institutions to attract and retain talent.
However, if States cannot ensure that their investment translates into a local specialist workforce, their incentive to fund medical education diminishes.
Without domicile reservations, States may deprioritise medical college funding, leading to declining infrastructure and worsening regional health-care disparities.
Freedom for AIIMS
This stands in contrast / opposite to premier central institutions such as the All India Institute of Medical Sciences (AIIMS), the Postgraduate Institute of Medical Education and Research (PGIMER), and the Jawaharlal Institute of Postgraduate Medical Education and Research (JIPMER), which are granted selection autonomy.
Right to adequate health care
Article 21 of the Indian Constitution guarantees the right to life, including access to adequate health care, while public health remains under State legislative competence.
मेडिकल कॉलेज राज्यों के लिए कितने महत्वपूर्ण है ?
Medical colleges are not merely institutions of higher education; they are also a crucial part of the State’s health infrastructure.
Viewing them solely as centres for producing medical graduates is a limited perspective.
State autonomy
Given the role of State government medical colleges in sustaining public health,
it is essential to recognise the State government’s need for autonomy in the selection process at the undergraduate, post-graduate and super-specialty levels.
This ensures that medical education
- aligns with local health-care needs,
- these institutions serve a greater purpose than academics alone.
Excessive centralisation
unwittingly powered by court rulings, restricts States from formulating policies suited to their public health needs and socio-economic circumstances.
The fallacy of absolute meritocracy
Meritocratic Framework
योग्यता आधारित ढांचा
एक ऐसी प्रणाली है जिसके निर्णय और पद लोगों की क्षमता, प्रतिभा और प्रदर्शन के आधार पर दिए जाते हैं, न कि उनकी सामाजिक पृष्ठभूमि, धन, या व्यक्तिगत संपर्कों के आधार पर।
. An analysis of the National Eligibility cum Entrance Test (Postgraduate), or NEET-PG, results reveals significant flaws in how merit is assessed, including instances where candidates with negative marks qualify due to percentile-based cutoffs.
A recent example from 2023 saw the National Medical Commission, following directives from the Ministry of Health, reduce the qualifying percentile for NEET PG and Super Speciality examinations to zero to fill vacant seats.
If undergraduate admissions recognise regional and socio-economic disparities, there is no reason for excluding such considerations from post-graduate admissions.
Furthermore, the judgment perpetuates a narrow conception of merit that disregards its social context. As noted in judgments on medical education in cases such as Jagdish Saran & Ors vs Union Of India & Ors (1982), Pradeep Jain (1984), Neil Aurelio Nunes & Ors vs Union of India (2022), and Om Rathod vs The Director General Of Health Services(2024), administrative efficiency should be measured not by abstract merit alone but by outcomes that promote societal good and redress structural inequalities.
acknowledged by the Economic Survey 2024-25 — domicile-based reservations
- enhancehealth-care access
- and mitigate regional disparities —
- aligning with a broader, more inclusive definition of merit.
Need for a reconsideration
While the Court’s ruling follows precedents from Pradeep Jainand the Constitution Bench, it merits re-evaluation.
The original framework, which drew a rigid line between undergraduate and post-graduate admissions, was formulated in a different health-care landscape.
स्टेट रिजर्वेशन की सबसे जयदा जरुरत कब फील हुई
particularly in light of crises such as the COVID-19 pandemic and the rising burden of non-communicable diseases.
तमिलनाडु से सीख
a more balanced approach would integrate these reservations with public service obligations.
For instance, Tamil Nadu’s medical education framework links quotas to service mandates in public institutions, ensuring that State investment yields tangible health-care benefits. Such models deserve greater judicial and policy consideration rather than outright dismissal.
A reconsideration of this verdict -
is imperative to ensure that States retain the autonomy necessary to structure their medical education policies in alignment with their health-care priorities.
Contrary to the Court’s concerns that domicile quotas pose a grave national risk, over-centralisation threatens federal health policy.
If India aims to build a robust and sustainable health-care system, judicial doctrine must evolve to accommodate the complex interplay between medical education, federalism, and public health policy.
Source the hindu
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