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Supreme Court Ruling on Domicile-Based Reservations
Context:
The recent Supreme Court judgment in Dr. Tanvi Behl vs. Shrey Goyal (2025), which struck down domicile-based reservations in post-graduate medical admissions, marks a pivotal shift in India’s medical education policy.
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- By ruling that such reservations violate Article 14 of the Constitution, the Court has dismantled a mechanism that States have long relied upon to build a stable medical workforce tailored to their public health needs.
- While the judgment upholds meritocracy, it overlooks the intricate relationship between medical education policies and State-level health planning.
- This decision introduces a centralising bias in India’s medical education framework, potentially discouraging States from investing in government medical colleges and turning competitive federalism into a race to the bottom.
Role of Domicile Quotas in State Health Planning
- Domicile-based reservations in post-graduate medical courses are a crucial policy tool for States to align their investment in medical education with long-term healthcare workforce retention.
- States invest substantial resources in training medical students, anticipating that these graduates will contribute to their local healthcare systems.
- Given the chronic shortage of specialists, domicile quotas provide a steady supply of doctors who are familiar with the State’s healthcare landscape.
- The Court’s reliance on Pradeep Jain vs. Union of India (1984) to strike down domicile-based reservations fails to recognise the fundamental difference between undergraduate and post-graduate education.
- While MBBS programs lay the groundwork for medical knowledge, post-graduate training is the primary means through which States develop a specialist workforce.
- The removal of domicile quotas disrupts this pipeline, leaving States dependent on external recruitment—a process that is often uncertain and inefficient.
- By eliminating domicile quotas, the ruling weakens States’ incentives to invest in medical education.
- A healthy system of competitive federalism should encourage States to develop strong institutions that attract and retain talent.
- However, if States cannot ensure that their investment translates into a local specialist workforce, they may deprioritise funding for medical education.
- This could lead to a decline in infrastructure and widen regional healthcare disparities.
- The ruling also contrasts sharply with premier central institutions such as the All India Institute of Medical Sciences (AIIMS) and the Postgraduate Institute of Medical Education and Research (PGIMER), which retain autonomy over their selection processes.
- State medical colleges—arguably even more vital to India’s public health system—are now denied similar prerogatives, leaving States at a disadvantage in planning for long-term healthcare needs.
- Article 21 of the Indian Constitution guarantees the right to life, which includes access to adequate healthcare, while public health remains a State legislative competence.
- Government medical colleges serve a dual role: they are not just institutions of higher learning but also critical components of a State’s healthcare infrastructure.
- Over-centralisation, whether through judicial or policy interventions, limits States from tailoring policies to meet their unique public health needs.
- A more flexible approach that respects the role of State government medical colleges in sustaining healthcare systems is essential.
- Government medical colleges serve a dual role: they are not just institutions of higher learning but also critical components of a State’s healthcare infrastructure.
Limitations of Absolute Meritocracy
- The Supreme Court’s insistence on a rigid meritocratic framework disregards the structural inequities in India’s medical entrance system.
- Analysing National Eligibility cum Entrance Test (Postgraduate), or NEET-PG, results reveals significant flaws in how merit is assessed.
- For instance, in 2023, the National Medical Commission, under the Health Ministry’s directive, reduced the qualifying percentile for NEET-PG and Super-Speciality exams to zero to fill vacant seats.
- This raises questions about the robustness of a purely exam-based merit system.
- If undergraduate admissions consider regional and socio-economic disparities, there is little justification for excluding these factors from post-graduate admissions.
- Court rulings such as Jagdish Saran & Ors vs. Union Of India (1982), Pradeep Jain (1984), and Neil Aurelio Nunes & Ors vs. Union of India (2022) have acknowledged that merit should not be viewed in isolation but rather in the context of promoting societal good and addressing structural inequalities.
- Domicile-based reservations, by prioritising candidates more likely to remain and serve in their home States, enhance healthcare access and mitigate regional disparities—aligning with a more inclusive definition of merit.
Need for Policy Reconsideration
- While the Court’s decision follows precedents from Pradeep Jain and the Constitution Bench, it warrants re-evaluation.
- The rigid distinction drawn between undergraduate and post-graduate admissions was formulated in a vastly different healthcare landscape.
- Today, the retention of specialists within State health systems is more critical than ever, especially in light of challenges such as the COVID-19 pandemic and the rising burden of non-communicable diseases.
- Rather than eliminating domicile quotas outright, a balanced approach would integrate these reservations with public service obligations.
- Tamil Nadu’s medical education framework, for instance, links quotas to mandatory service in public institutions, ensuring that State investment translates into tangible healthcare benefits.
- Such models merit judicial and policy consideration rather than outright dismissal.
