Author: Shruthika. S, B.A.LL.B (Hons.), Tamil Nadu National Law University (TNNLU)
To the Point
On January 29, 2025, India’s Supreme Court made a historic decision in the case of Dr. Saumya Singh v. State of Uttar Pradesh & Ors. The Court ruled that reserving postgraduate medical seats based on where someone is from that is, their domicile is unconstitutional. They decided that such a reservation goes against the fundamental right to equality protected by Article 14 of the Constitution and also affects the fairness and merit-based nature of medical admissions. This verdict is a major step in how India approaches reservations; it shifts the focus toward balancing affirmative action with the need to ensure merit in highly competitive professional courses. The case has sparked renewed discussions, both legally and politically, about how much independence the state has in offering domicile-based preferences versus the constitutional obligation to treat everyone equally.
Abstract
This article critically analyzes the Supreme Court’s 2025 decision to strike down domicile-based reservations in postgraduate medical admissions. While states have traditionally defended such quotas as necessary to retain local professionals and address regional disparities in healthcare, the Court took a firm stance that merit should not be compromised in the context of advanced medical education. The discussion delves into the Court’s legal reasoning, relevant constitutional provisions, and the wider societal consequences of the judgment. By situating the ruling within the ongoing debate over affirmative action and equal opportunity, the article raises important questions: Does this decision signal a new judicial approach to state-specific reservations? And what might it mean for the future of educational equity in India?
Use of Legal Jargon
The constitutional validity of reservation policies hinges upon the harmonious interpretation of Articles 14, 15, and 16 of the Indian Constitution. While Article 15(4) and Article 15(5) permit affirmative action for socially and educationally backward classes, the use of domicile as a classification raises questions of intelligible differentia under Article 14. The Court reiterated the doctrine of reasonable classification and proportionality while applying the principle of non-arbitrariness to invalidate the domicile-based quota in PG medical seats.
The Proof
In this case, the Uttar Pradesh government had introduced a policy reserving 50% of PG medical seats in government colleges for candidates who had completed their MBBS from institutions within the state. This effectively barred meritorious candidates from other states, including those who were Indian citizens and had cleared national entrance exams.
The Supreme Court, in a bench comprising Justices B.V. Nagarathna and Augustine George Masih, held that:
Medical education, especially at the postgraduate level, is a matter of national interest, and not merely a state concern.
Reservation based purely on geographical criteria (domicile or place of study) without considering socio-economic or educational backwardness is unconstitutional.
The principle of merit must be upheld in PG medical admissions, where specialization impacts public health delivery across the country.
The Court underscored that such policies are incompatible with the objective of producing the best medical professionals for national service. It also clarified that Article 15(4) cannot be invoked to create reservations solely based on state lines without any socio-educational rationale.
Case Laws
Dr. Pradeep Jain v. Union of India, (1984) 3 SCC 654
A foundational case where the Supreme Court permitted limited domicile-based reservation in MBBS admissions but disapproved of its use in postgraduate courses, stressing the importance of national merit. The 2025 judgment reaffirmed this precedent.
Saurabh Chaudhary v. Union of India, (2003) 11 SCC 146
The Court upheld limited institutional preference in PG admissions but warned against excessive regionalism. The 2025 judgment narrowed even this limited scope.
Kailash Chand Sharma v. State of Rajasthan, (2002) 6 SCC 562
This case struck down excessive weightage for local candidates in state employment, reinforcing that domicile-based preferences must not override equality and merit.
Conclusion
The 2025 Supreme Court judgment striking down domicile-based reservation in PG medical education is a watershed moment in Indian constitutional jurisprudence. It affirms the centrality of merit in professional education and curbs the trend of regional parochialism in admission policies. While states have a legitimate interest in addressing local shortages of doctors, such goals must be pursued through constitutionally permissible means—such as incentive-based rural postings or special training programs—rather than exclusionary quotas.
This ruling signal a stricter judicial scrutiny of state policies that rely on geographical criteria and emphasizes a unified national approach to professional excellence. As India grapples with questions of equity and excellence, this judgment sets the tone for a more merit-driven and constitutionally consistent framework in education.
FAQS
What was the main issue in this case?
The main issue was whether the Uttar Pradesh government’s 50% reservation in PG medical seats for domicile candidates violated Article 14 (equality) of the Constitution.
Did the Supreme Court allow any domicile-based reservation?
No. The Court held that domicile-based reservations in postgraduate medical education are unconstitutional, especially in the absence of socio-educational justification.
What precedent did the Court rely on?
The Court relied heavily on Dr. Pradeep Jain v. Union of India (1984), where domicile-based reservations were discouraged in PG admissions.
Why is PG medical education treated differently from UG education in reservation policy?
Postgraduate education involves specializing in a particular field and plays a key role in how healthcare services are delivered. The Court made it clear that, when selecting candidates at this level, their merit should be the most important factor.
Will this judgment affect other state-level reservations?
Potentially, yes. It could influence judicial review of similar domicile-based policies in other states and sectors, especially where merit and national interest are implicated.
