Introduction

In a landmark judgment in Tanvi Behl v. Shrey Goel and others (2025), the Supreme Court of India (SC) ruled that domicile-based reservations in PG medical courses are unconstitutional, violating Article 14 (Right to Equality). This ruling reaffirmed the merit-based selection principle for PG medical seats and upheld the constitutional unity of Indian citizenship.

The judgment overturns previous state policies that allocated a portion of PG medical seats for residents of specific states, thus eliminating barriers to professional mobility and ensuring a national merit-based system.

Key Takeaways from the Supreme Court Ruling

1. Violation of Right to Equality (Article 14)

• State-wise domicile-based reservations create discrimination among students based on their place of residence.
• The Constitution only recognizes a single domicile—"Domicile of India" (Article 5), rejecting state-specific domicile concepts.
• As per the ruling, Indian citizens have the right to reside and practice their profession anywhere in the country without restriction.

2. Merit-Based Admissions Must Prevail

• PG medical admissions must be based solely on merit through NEET scores, even for state quota seats.
• Institutional preference in PG admissions may be allowed to a reasonable extent, but residence-based reservations are unconstitutional.

3. Past Admissions Remain Unaffected

• The ruling will not impact students who have already been admitted under domicile-based reservations.
• Future admissions must follow strictly merit-based criteria.

4. Domicile vs. Residence: A Legal Distinction

• The Court clarified that domicile refers to a permanent legal home, whereas residence is a temporary stay in a particular location.
• The concept of state domicile for PG admissions contradicts the constitutional framework.

5. Precedents Cited by the Court

• Pradeep Jain v. Union of India (1984): Allowed limited residence-based reservations for UG (MBBS) but ruled them unconstitutional for PG medical admissions.
• Saurabh Chaudri v. Union of India (2003): Reaffirmed that PG medical admissions should be merit-based, allowing only institutional preference.
• Jagadish Saran v. Union of India (1980): Stated that talent at higher levels of education must not be compromised as it is crucial for national progress.

Pros and Cons of Domicile-Based Reservations

✅ Arguments in Favor of Domicile Reservations

1.   Encourages Local Talent Development: Ensures local students get access to higher education in their own states.

2.   Addresses Regional Disparities: Helps backward regions develop a skilled workforce.

3.   Enhances Local Healthcare Systems: More local doctors may stay and serve their home states after completing PG courses.

Arguments Against Domicile Reservations

1.   Violates Fundamental Rights: Restricts the freedom to move, study, and practice a profession anywhere in India (Article 19).

2.   Fragmentation of National Unity: Promotes regionalism, creating artificial barriers in education and employment.

3.   Compromises Meritocracy: Reduces competition and quality in higher medical education.

4.   Economic and Professional Setbacks: Limits national talent mobility, discouraging private sector growth and investment in healthcare.

Way Forward: A Merit-Based and Inclusive Approach

1. Strengthen National-Level Admissions

• Uniform admission process based on NEET merit to ensure equal opportunities.
• Avoid state-level quotas based on domicile but allow reasonable institutional preference.

2. Improve Medical Infrastructure Nationwide

• Instead of restricting PG seats, governments should enhance medical infrastructure in backward regions.
• More PG seats, scholarships, and incentives for doctors to work in underdeveloped areas.

3. Targeted Support for Underprivileged Communities

• Instead of domicile-based quotas, affirmative action for socio-economically disadvantaged groups should be prioritized.
• Skill development and financial assistance should replace regional reservations.

4. National Integration Over Regional Preferences

• Admission policies must be framed keeping in mind India’s single citizenship and uniform rights for all.
• Reservation policies should focus on real disadvantage (SCs, STs, OBCs, EWS) rather than residence.

Conclusion

The Supreme Court’s ruling on domicile-based PG medical admissions reinforces the principles of equality, meritocracy, and national integration. By striking down state-based domicile quotas, the Court has paved the way for merit-driven medical education, ensuring that talent, not location, determines success in higher education.

For India’s healthcare sector to progress, policies should focus on expanding access to quality education and strengthening healthcare systems, rather than creating artificial barriers based on domicile.

Introduction

The Supreme Court, in Tanvi Behl v. Shrey Goel and Others (2025), ruled that domicile-based reservations for PG medical admissions are unconstitutional, citing violations of Article 14 (Right to Equality). The judgment underscores the primacy of merit-based selection and rejects state-specific domicile as a valid criterion, reinforcing the idea of national integration in higher education.

Constitutional Implications

1.   Violation of Article 14 (Right to Equality)

o    Domicile-based reservations create artificial barriers by favoring local students over equally qualified candidates from other states.

o    The Constitution grants equal protection of laws to all citizens, making state-wise reservation discriminatory.

2.   Reinforcement of Single Domicile Concept (Article 5)

o    The ruling reaffirms that India recognizes only one domicile—Domicile of India.

o    State-specific domicile policies contradict the unified citizenship framework of the Constitution.

3.   Interpretation of Articles 15 and 16

o    While Article 15(4) and 16(4) permit reservations for backward classes, they do not explicitly provide for domicile-based reservations.

o    The Court clarified that regional preference cannot override merit in PG medical education.

Policy Implications

1.   Merit-Based Admissions Over Regional Preferences

o    The ruling ensures PG medical seats are allocated based on NEET merit, improving the quality of medical professionals.

o    It prevents regional favoritism, fostering a nationally competitive medical education system.

2.   Impact on State Autonomy in Education

o    States invest heavily in medical education and argue that local candidates should benefit from public resources.

o    The judgment limits state control over admissions but allows institutional preference to a reasonable extent.

3.   Challenges in Healthcare Access for Backward Regions

o    Removing domicile quotas may reduce the availability of doctors in underserved areas.

o    States may need alternative incentives, such as bonded service agreements or higher stipends for rural postings, to retain medical talent.

4.   National Integration and Mobility of Professionals

o    By eliminating state-specific restrictions, the ruling promotes professional mobility, allowing doctors to practice anywhere in India.

o    This fosters better talent distribution across the country, benefiting national healthcare outcomes.

Conclusion

The Supreme Court’s ruling strengthens constitutional principles of equality and meritocracy, ensuring fair access to PG medical education. While it addresses discriminatory state policies, states must now focus on improving medical infrastructure and providing targeted incentives rather than relying on domicile-based reservations to retain medical talent. The decision marks a shift towards a unified and merit-driven medical education system, balancing constitutional values with national healthcare needs.

1. With reference to the Supreme Court’s ruling on domicile-based reservations in PG medical admissions, consider the following statements:

1.   The Court held that domicile-based reservations violate Article 14 (Right to Equality) of the Indian Constitution.

2.   The ruling applies to both undergraduate (MBBS) and postgraduate (PG) medical admissions.

3.   The judgment is based on the principle that India recognizes only one domicile—Domicile of India under Article 5.

4.   The decision mandates that all PG medical seats must be filled strictly based on NEET merit, except for institutional preferences.

Which of the statements given above are correct?

(a) 1, 3, and 4 only
(b) 2 and 4 only
(c) 1 and 2 only
(d) 1, 2, 3, and 4

Answer: (a) 1, 3, and 4 only

Explanation: The ruling applies only to PG medical admissions, not MBBS, where limited residence-based reservations are allowed.

2. Which constitutional article primarily served as the basis for the Supreme Court’s decision to strike down domicile-based reservations for PG medical courses?

(a) Article 15 – Prohibition of Discrimination
(b) Article 16 – Equality in Public Employment
(c) Article 14 – Right to Equality
(d) Article 19 – Freedom of Movement

Answer: (c) Article 14 – Right to Equality

Explanation: The Court ruled that domicile-based quotas violate Article 14, as they create unreasonable classifications among citizens based on state residency.

3. What was a key distinction made by the Supreme Court between undergraduate (MBBS) and postgraduate (PG) medical admissions regarding domicile-based reservations?

(a) Domicile-based reservations are constitutionally valid for both MBBS and PG courses.
(b) The Court permitted some residence-based reservations for MBBS but declared them unconstitutional for PG admissions.
(c) The Court completely banned domicile-based reservations in both MBBS and PG courses.
(d) The Court ruled that states can decide their own domicile criteria for both MBBS and PG admissions.

Answer: (b) The Court permitted some residence-based reservations for MBBS but declared them unconstitutional for PG admissions.

Explanation: In Pradeep Jain v. Union of India (1984), the Supreme Court allowed limited domicile-based reservations for MBBS, citing state investment in medical education, but ruled them unconstitutional for PG admissions, where merit must prevail.

4. The Supreme Court's judgment on domicile-based reservations in PG medical admissions is based on which of the following principles?

(a) State governments have complete autonomy in determining admission policies.
(b) Merit-based admissions must be prioritized over regional considerations.
(c) Every state has the right to implement domicile-based quotas in higher education.
(d) PG medical admissions should have a fixed percentage of seats reserved for local students.

Answer: (b) Merit-based admissions must be prioritized over regional considerations.

Explanation: The ruling emphasizes that PG medical seats should be allotted based on merit, ensuring that the most qualified candidates secure admission regardless of their state of residence.

5. Which of the following is a major implication of the Supreme Court’s ruling on domicile-based PG medical admissions?

(a) All reservations in medical education, including those for Scheduled Castes and Scheduled Tribes, are unconstitutional.
(b) States must now allocate PG medical seats strictly based on merit, with no provision for domicile-based preferences.
(c) State governments can still enforce domicile-based reservations in all medical institutions without any restrictions.
(d) The ruling applies only to private medical colleges and does not impact government-run institutions.

Answer: (b) States must now allocate PG medical seats strictly based on merit, with no provision for domicile-based preferences.

Explanation: The Supreme Court ruled that PG medical admissions must be based entirely on merit, and domicile-based quotas are unconstitutional. However, institutional preferences may still be allowed within reasonable limits.