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2025 Supreme(SC) 247

HRISHIKESH ROY, SUDHANSHU DHULIA, S. V. N. BHATTI
Tanvi Behl – Appellant
Versus
Shrey Goel – Respondent


Judgement Key Points

Certainly. Based on the provided legal document, here are the key points:

  1. The court has declared that domicile or residence-based reservation in PG Medical Courses within a State is unconstitutional and violates the principles of equality enshrined in Articles 14 and 15 of the Constitution (!) (!) .

  2. The primary issue addressed is whether such residence-based reservations are legally permissible. The court's definitive stance is that they are not, and the practice of reserving seats based on residence or domicile is constitutionally invalid (!) .

  3. The Court reaffirmed that merit, as determined by a national-level examination (NEET), must be the basis for admissions to PG Medical Courses. Residence-based reservations undermine equal opportunity and are inconsistent with the constitutional guarantee of equality (!) (!) .

  4. The concept of domicile in Indian law is clarified to be a single, national concept—‘domicile in India’—and does not vary by State. The idea of a regional or State domicile is a misconception; all citizens are considered to have only one domicile, which is the domicile of India (!) (!) .

  5. The Court emphasized that residence or permanent residence is different from domicile, and the latter is a legal concept that signifies the ‘place of living’ or ‘permanent residence’ in a legal sense, which in India is uniformly ‘India’ (!) (!) .

  6. The Court highlighted that the use of ‘domicile’ terminology by State authorities often reflects a misconception, as the legal system recognizes only one domicile for each citizen—India-wide—regardless of residence within specific States (!) (!) .

  7. The Court noted that residence-based reservations are permissible at the undergraduate (MBBS) level under certain conditions, primarily because of the State's expenditure and infrastructural investments. However, at the PG level, merit must be the sole criterion, and residence cannot be used as a basis for reservation (!) (!) .

  8. The Court observed that allowing residence-based reservations at the PG level would violate the fundamental rights to equality and equal protection under the law, as it would unjustly discriminate against students from other States who have achieved merit-based ranks (!) .

  9. The Court clarified that reservations already granted on the basis of residence or domicile will not be disturbed, especially for students who are currently undergoing or have completed their PG courses, to maintain fairness and equity (!) .

  10. The overall ruling reinforces that the reservation system must align with the constitutional principles of equality, merit, and non-discrimination, and that residence or domicile cannot be a criterion for PG Medical admissions (!) (!) .

Please let me know if you need a detailed analysis or specific legal advice based on this document.


Table of Content
1. chandigarh medical college admissions (Para 1 , 2 , 3)
2. high court's findings (Para 4 , 5 , 6 , 7 , 8)
3. merit must prevail (Para 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34)
4. appeal disposed (Para 35 , 36)

JUDGMENT :

(Sudhanshu Dhulia, J.)

1. The question before this Court is whether residence-based reservation in Post Graduate (PG) Medical Courses by a State is constitutionally valid? On this the precise questions formulated by the Division Bench of this Court, which have now come up for determination before this Court, are as follows:

    “1. As to whether providing for domicile/residence-based reservation in admission to "PG Medical Courses" within the State Quota is constitutionally invalid and is impermissible?

    2. (a) If answer to the first question is in the negative and if domicile/residence-based reservation in admission to "PG Medical Courses" is permissible, what should be the extent and manner of providing such domicile/residence- based reservation for admission to "PG Medica

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