The Chhattisgarh High court (Bilaspur Bench) clarified that while granting admissions, especially to higher and specialised courses, merit must prevail to safeguard educational standards, while pointing out that relaxing merit at such levels under the guise of institutional reservation or domicile reservation would risk compromising critical professional excellence.
The Court therefore quashed Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, being ultra vires and violative of Article 14 of the Constitution, holding that the State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025.
The Division Bench comprising Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru observed that reiterated that if equality of opportunity for every person in the country is the constitutional guarantee, a candidate who gets more marks than another is entitled to preference for admission. Merit must be the test when choosing the best, according to this rule of equal chance for equal marks.
Reference was made to the decision of the Apex Court in the case of Tanvi Behl v. Shrey Goel & Others [Civil Appeal No. 9289/2019], where it was held that residence-based reservation is impermissible in PG Medical courses, the State quota seats, apart from a reasonable number of institution-based reservations, have to be filled strictly on the basis of merit in the All- India examination.
Thus, the Bench concluded that the institution-based preference granted to alumni of State-affiliated medical colleges operated as a de-facto reservation and was unconstitutional.
Briefly, the petitioner, a permanent resident of Chhattisgarh, had completed schooling in Bilaspur and subsequently secured admission to an MBBS course in Tamil Nadu through All India counselling. After completing the MBBS degree and internship, the petitioner appeared in NEET-PG 2025, qualified the examination, and became eligible for PG medical admission.
Now, according to the petitioner, the provisions of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, created two distinct categories of candidates, as to those who obtained MBBS degrees from medical colleges within Chhattisgarh and those who obtained such degrees from outside the State despite being permanent residents of Chhattisgarh. It was argued that such classification was arbitrary and contrary to the constitutional prohibition against residence-based discrimination in postgraduate medical admissions.
Cases Relied On:
Tanvi Behl v. Shrey Goel & Others [Civil Appeal No. 9289/2019]
Sawan Bohra & Another vs. State of M.P. & Others [WP No. 38169/2025]
Appearances:
Senior Advocate Rajeev Shrivastava, along with Advocates Sandeep Dubey, Manas Vajpai and Kaif Ali Rizvi, for the Petitioner
Deputy Advocate General Shashank Thakur, along with Advocates Shreya Pawan Daga, Dheeraj Wankhede, and Anmol Sharma, for the Respondent
