Facts of the case
The case involved admissions to undergraduate (UG) and postgraduate (PG) medical courses across various states and union territories in India. The general policy followed by these institutions was to give preference to students who either held domicile status or had been permanent residents of the state for a significant period, ranging from 3 to 20 years, or had completed their education in that state for a period between 4 to 10 years. The dispute arose when the petitioner, who held domicile status at the time of admission, faced restrictions due to these domicile and institutional preference policies. The petitioner challenged the order of the Delhi High Court before the Supreme Court, seeking admission to MBBS and MDS courses in different universities across multiple states and the Union Territory of Delhi. The central issue before the Supreme Court was whether a state-run medical or higher education institution could restrict admissions only to students who met domicile or residency requirements, giving them priority over non-residents, irrespective of merit.
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Issues
The legal issue in this case is whether a state can limit admissions to medical colleges or other educational institutions only to students who have lived there for a long time or have a domicile in that state. Additionally, it raises the question of whether a state government can give preference in admissions to students with domicile status over those who are purely admitted based on merit. Essentially, the case examines whether a state can prioritize its own residents in educational opportunities and if such a policy aligns with constitutional principles of equality and fairness in admissions.
Petitioner’s Arguments
The petitioners challenged the admission policy that required applicants to meet a domicile requirement, arguing that it violated the right to equality under Articles 14, 15, 19, and 301 of the Indian Constitution. They contended that setting residential qualifications for employment or public office was unconstitutional, citing the broad definition of "State" in Ramana Dayaram Shetty v. International Airport Authority of India.
Respondent's Arguments
On the other hand, the respondents defended the policy, asserting that Article 16(2) was not relevant in this case because it specifically prohibits discrimination based on place of birth in public employment, not residence. They argued that since the eligibility condition in question pertained to residence rather than birthplace, it did not violate Article 16(2).
Analysis of the Court
The Supreme Court, while dismissing the petition, clarified that not all forms of discrimination violate the constitutional principle of equality or threaten national unity. The Court emphasized that Article 14 of the Constitution does not prohibit all distinctions but only those that are arbitrary or unjustified. A classification is valid if it is based on a reasonable ground and serves a legitimate purpose. In this context, the Court upheld reservations based on domicile, stating that such policies help address regional disparities and ensure fair opportunities for people from underprivileged areas. By allowing domicile-based reservations, the Court reinforced the idea that true equality is not about treating everyone the same but about ensuring fair access to opportunities, particularly for those who need it the most.
