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2025 Supreme(Telangana) 831

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
SUJOY PAUL, A.C.J., RENUKA YARA, JJ.
Chemudugunta Neeharika and others - Appellants 
Versus 
The State of Telangana and another - Respondents
Writ Petition Nos.1255, 1359, 2493, 2501, 2506 and 2507 of 2025
Decided on : 10-02-2025

Advocates Appeared:
For the Petitioners: Sri B. Mayur Reddy, learned Senior Counsel representing Sri Alluri Divakar Reddy, Sri S. Abhaya Kumar Sagar and Sri Anjanayulu Yadanaboyina, learned counsel
For the Respondents:Sri A. Sudharshan Reddy, learned  Advocate General for the State of Telangana, Sri T. Sharath, learned counsel for Kaloji Narayana Rao University of Health Sciences.

Caste certificates from one state are not valid for educational admissions in another state, regardless of recognition as Scheduled Castes in both, affirming constitutional provisions and prior Supreme Court rulings.

Headnote:(A) Constitution of India - Article 341 - Challenges to caste certificate recognition in educational admissions - Petitioners argued that their eligibility under Scheduled Caste status should be recognized based on certificates from a unified state, citing relevant Supreme Court judgments - Court reaffirmed that caste certificates issued in one state are not valid in another, thus upholding the legality of the prospectus clause excluding such certificates. (Paras 6, 27, 29)

(B) Education - Admission Policy - The court emphasized that modifications to eligibility criteria should not disadvantage candidates mid-process, referencing the principle of fairness. (Paras 15, 26)

Facts of the case:
The petitioners challenged a prospectus clause that barred recognition of their Scheduled Caste certificates from Andhra Pradesh when applying for PG medical admissions in Telangana, arguing for continuity of eligibility rights post-state bifurcation.

Findings of Court:
The court upheld the legality of the prospectus clause, determining that caste certificates from Andhra Pradesh were not valid in Telangana, affirming prior constitutional judgments.

Issues: The main issue addressed was the validity of caste certificates from Andhra Pradesh in Telangana and whether the prospectus clause altered eligibility criteria unfairly mid-admission process.

Ratio Decidendi: The court concluded that unless specified by competent authorities in the state of admission, caste certificates issued by another state do not confer rights to reservation, binding interpretation from constitutional judgments was upheld.

Result: All petitions dismissed.

Table of Content
1. petitioner challenges legality of admission criteria. (Para 2 , 3 , 4 , 5)
2. petitioners argue for recognition of caste certificates. (Para 6 , 7)
3. respondents assert state's authority over admission criteria. (Para 8 , 9 , 10)
4. analysis of prospectus versus constitutional provisions. (Para 14 , 15 , 16)
5. caste certificates’ state-specific validity emphasized. (Para 17 , 18 , 19 , 20)
6. competent authorities for caste certificates defined. (Para 21 , 22)
7. previous judgments reaffirmed on caste eligibility. (Para 23 , 24 , 25 , 26)
8. final determination on lack of validity for caste certificates. (Para 27 , 28)
9. court dismisses petitions without relief. (Para 29)

ORDER :

SUJOY PAUL, A.C.J.

Regard being had to the similitude of the questions involved, these matters were analogously heard and decided by this common order.

Facts:-

2. The facts are taken from W.P.No.1255 of 2025. The petitioner has challenged the legality, validity and constitutionality of Clause 4.2 of the prospectus which according to her has an adverse impact on the prospects of the petitioner. The petitioner studied from 1st standard to 12th standard in the State of Andhra Pradesh and completed 12th standard in the year 2016. She appeared for NEET UG 2016 and secured admission through ‘B’ category on merit basis and allotted to Mallareddy Medical College for Women’s, Hyderabad, Telangana, for academic year 2016-17. Accordingly, she completed her MBBS course and passed Final examination in the month of April, 2021 with registration number 1601020028. She also completed her one year compulsory rotatory internship in the same college from 01.06.2021 and 31.05.2022. Though, she appeared for NEET PG 2022 and 2023, she could not secure good score.

3. The National Board of Examination in Medical Science (NBEMS) has issued Notification for Admission to Post Graduate courses NEET PG 2024 on 16.04.2024, exam was conducted on 11.08.2024 and results were declared on 23.08.2024. The petitioner appeared for the said examination with registration number PG24086163 and secured All India Rank of 51285. The petitioner belongs to Schedule Caste (SC) (Mala) Community and holds caste certificate issued by the State of Andhra Pradesh dated 24.04.2024, which certifies that she belongs to Mala (SC) Community, which is recognized as Scheduled Community/Caste under the Constitution (Scheduled Tribes) Order, 1950, Schedule Caste and Schedule Tribe List (Modification) Order, 1956 and the Schedule Caste and Schedule Tribe (Amendment) Act, 1976 as amended from time to time.

4. On 30.10.2024, Respondent No.2 issued prospectus for admissions into PG Medical Degree and Diploma Courses under the Competent Quota for 2024-2025. On the same day, a notification was also issued stating that online applications and certificates uploading shall begin at 06:00 AM on 31.10.2024 and close at 06:00 PM on 07.11.2024. Pursuant to the said notification, the petitioner registered for postgraduate medical admission under competent quota for the academic year 2024-25 by paying requisite fee.

5. The petitioner is not treated to be ‘local candidate’ in view of hurdle created by Rule VIII of the Telangana Medical Colleges (Admission into Postgraduate Medical Courses) Rules, 2021, as amended by G.O.Ms.No.148, dated 28.10.2024. Aggrieved, the petitioner assailed the said Rule in W.P.No.31317 of 2024, which was decided on 17.12.2024. In obedience of judgment of Division Bench in the said Writ Petition, the petitioner was treated as ‘local candidate’, but her caste certificate issued by the Government of Andhra Pradesh was not accepted. In the result, the petitioner was treated to be general category candidate and benefit of reservation was not given to her. The impugned Clause 4.2 became part of the prospectus with effect from 16.04.2024, whereas the admission process began much before that.

Contention of the petitioners:-

6. The petitioners in all these Writ Petitions have assailed the prospectus and a

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