MP High Court Voids 100% Institutional Preference in PG Medical Seats

In a significant ruling protecting the principles of meritocracy in higher education, the High Court of Madhya Pradesh has invalidated a state government amendment that effectively reserved 100% of postgraduate medical seats in private colleges for students who completed their MBBS within the state.

The bench, comprising Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf, held that institutional preference—in any form—must adhere to the "50% ceiling" rule established by the Supreme Court. The judgment reinforces that when it comes to higher education specialties, national merit cannot be sacrificed at the altar of local preference.

The Backdrop: A Barrier to Merit

The dispute arose following a notification issued on September 3, 2025, which introduced a mandate requiring candidates for postgraduate medical courses in private colleges to have graduated from an institution within Madhya Pradesh.

While the state government argued that this policy encouraged institutional continuity and retained local talent, the petitioners—MBBS graduates aspiring for PG seats—challenged the amendment. They argued that the policy created a "wholesale reservation," blocking meritorious students from across India and violating foundational constitutional requirements under Article 14.

The State’s Defense vs. Constitutional Reality

The State of Madhya Pradesh attempted to justify the classification by citing the unique healthcare needs of the region, claiming that local students are better suited to address regional disease profiles. They maintained that the policy was not a blanket reservation, as it allowed for outsiders to participate if seats remained vacant after the first round of counseling.

However, the Court found this justification "superficial." Crucially, the Court noted that because the rules prevented non-local candidates from registering for the first round, those candidates were effectively barred from participating in later rounds. Furthermore, given the scarcity of PG seats, relying on "leftover" seats was mathematically unlikely to offer any meaningful opportunity to outside candidates.

Lessons from the Supreme Court

The High Court’s reasoning was firmly anchored in the precedents of the Supreme Court of India, specifically: * Pradeep Jain vs. Union of India : Established the outer limit of 50% for all reservations, including institutional preference. * Saurabh Chaudri vs. Union of India : Reaffirmed the 50% limit, emphasizing that the Constitution is a "living organ" that must evolve, but must not deviate from the core requirement of merit. * Tanvi Behl vs. Shrey Goel : Categorically ruled that, while institutional preference is valid, domicile-based reservation in PG medical courses is impermissible.

Key Observations

The judgment delivered by Chief Justice Sanjeev Sachdeva highlights the high stakes of professional medical training:

> "The basic medical needs of a region or the preferential push justified for a handicapped group cannot prevail in the same measure at the highest scales of speciality where the best skill or talent must be handpicked by selecting according to capability."

> "As the reservation in private colleges in one form or other exceeds 50%, same cannot be countenanced. As noticed hereinabove, 100% reservation is being given... which as per the Supreme Court is not permissible."

> "We hold that reservation in all categories cannot exceed 50% of the total seats in Private Medical Colleges (including 15% NRI quota and 30% in-service candidates seats)."

Final Verdict and Impact

The petition was allowed, and the Court has directed the State to permit all aspirants to register for the counseling process. The order mandates that the total reservation—comprising NRI quotas, in-service candidates, and institutional preferences—must not exceed the 50% total capacity.

This ruling serves as a stern reminder to state authorities: policies designed to prioritize local interests must remain subordinate to the constitutional guarantee of equal opportunity. For thousands of medical graduates, the decision restores the promise that national excellence, not local residence, is the primary gateway to specialized training.