Closing the Doors on Inter-State Reservation: Rajasthan HC Rules on NEET PG Counseling

In a significant judicial development for postgraduate medical education, the Rajasthan High Court has categorically upheld the state’s decision to limit reservation benefits—and their associated qualifying percentile relaxations—to candidates holding a bonafide domicile in the State of Rajasthan.

The decision, delivered by Justice Sanjeet Purohit on April 13, 2026, brings much-needed clarity to the intense confusion surrounding the "stray vacancy" rounds of NEET PG counseling, where students from other states had challenged their classification as "General" category candidates.

The Backdrop: A Dispute Over Eligibility

The controversy stemmed from the Federation of Private Medical and Dental College of Rajasthan’s challenge to the minutes of a meeting held on February 18, 2026. The Federation argued that by treating candidates from other states as "General/Unreserved"—and subsequently denying them the reduced qualifying percentile threshold allowed for reserved categories by the Central Government—the state authorities were acting arbitrarily.

For the petitioner, the crux of the issue was simple: with numerous postgraduate seats remaining vacant despite the national push to fill them, the state should allow reserved-category students from other states to fill those seats using the lower, category-specific cut-offs.

Arguments from the Trenches

The Federation, represented by Senior Counsel M.S. Singhvi, claimed that the state's move amounted to a "100% domicile-based reservation," which they argued was unconstitutional. They drew parallels to a previous instance where a student had been admitted using a reserved-category score for a general seat, labeling the current policy a "change of rules mid-way."

Conversely, the State of Rajasthan, through its legal counsel, anchored its defense in the concept of constitutional federalism. They argued that reservation is a state-specific identity. According to the state’s Instruction Booklet, the benefits of reservation under the Rajasthan Act of 2008 apply exclusively to bonafide residents of the state. They highlighted that allowing "cross-state" reservation would not only jeopardize the rights of the state's own disadvantaged groups but would also violate the settled law on state-specific scheduled castes and tribes.

Judicial Reasoning: Defining the Scope of Equity

Drawing upon a long line of Supreme Court jurisprudence, including * Marri Chandra Shekhar Rao v. Seth G.S. Medical College * and * Bir Singh v. Delhi Jal Board *, Justice Purohit emphasized that reservation benefits are strictly bound by the geographical territory of a state. The court held that the categorization of SC/ST/OBC groups is unique to the social and economic conditions of a specific state.

Addressing the claim that the policy resulted in "100% domicile-based reservation," the court dismissed the notion:

> "Since reserved category candidates belonging to other States are allowed to participate against unreserved seats, the impugned decision does not, either in form or in substance, amounts to 100% domicile based reservation."

The court further noted that while seats going vacant is a national concern, the preservation of academic merit at the postgraduate level cannot be sacrificed.

Key Observations

• On the Nature of Reservation: "The benefit of reservation is restricted to the State of origin and cannot be extended into the State to which one has migrated."
• On Merit Standards: "While postgraduate medical seats are regarded as being of national importance, this consideration cannot override the necessity of adhering to prescribed minimum standards of merit, particularly in postgraduate courses."
• On Legal Consistency: "There can be no compromise on merit in admission to PG medical courses... candidates who do not meet the prescribed qualifying criteria cannot be granted admission merely to ensure that seats do not remain vacant."

The Verdict and Its Impact

Ultimately, the Rajasthan High Court dismissed the petition, solidifying the sanctity of the state-specific reservation framework. The court clarified that candidates from other states are not barred from participating in the counseling process, provided they meet the eligibility criteria for the General/Unreserved category.

By refusing to permit what it termed "negative equality"—the use of one erroneous administrative instance to legalize a broader, unconstitutional practice—the court has provided a clear blueprint for future admissions. For medical aspirants, the ruling serves as a stern reminder that while the path to a postgraduate degree is rigorous, it must navigate the constitutional boundaries set by state laws and federal structures, ensuring that the integrity of the selection process remains intact.