DR. TANVI BEHL versus SHREY GOEL & ORS.

DR. TANVI BEHL versus SHREY GOEL & ORS.

Residence/domicile-based reservation in PG medical courses within the State quota is constitutionally invalid and impermissible under Article 14; institutional preference seats are permissible to a reasonable extent, and except for such reasonable institutional preference seats, State quota PG seats must be filled strictly on merit through the All-India examination; existing admissions granted under the residence category in the present cases will not be disturbed.

Parties
Appellant: Dr. Tanvi Behl; Respondent: Shrey Goel & Ors.; Interested Party: Government Medical College and Hospital, Chandigarh
Jurisdiction
India
Judgment Date
29 January 2025
Procedural Posture
Civil Appeal / Appeal From the Judgment and Order Dated 23.04.2019 of the High Court of Punjab & Haryana at Chandigarh in CWP No. 8234 of 2019
Outcome
Appeal disposed of; residence-based reservation in PG medical courses declared impermissible; institutional preference seats upheld; admissions already granted under the residence category in the present cases not disturbed
Legal Topics
Reservation in Education, Domicile Vs Residence, State Quota Admissions, Institutional Preference, Merit Based Admissions, PG Medical Admissions
Constitutional Law Education Law Administrative Law Reservation Law Reservation in Education Domicile Vs Residence State Quota Admissions Institutional Preference +2 more

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Parties

Dr. Tanvi Behl

Appellant

Shrey Goel & Ors.

Respondent

Government Medical College and Hospital, Chandigarh

Interested Party

Procedural Posture

Civil Appeal / Appeal From the Judgment and Order Dated 23.04.2019 of the High Court of Punjab & Haryana at Chandigarh in CWP No. 8234 of 2019

Legal Issues

  1. 1 Whether domicile/residence-based reservation in admission to PG Medical Courses within the State quota is constitutionally invalid and impermissible
  2. 2 Scope and permissibility of institutional preference in medical admissions
  3. 3 Distinction between domicile and residence in Indian law

Ratio Decidendi

Residence/domicile-based reservation in PG medical courses within the State quota is constitutionally invalid and impermissible under Article 14; institutional preference seats are permissible to a reasonable extent, and except for such reasonable institutional preference seats, State quota PG seats must be filled strictly on merit through the All-India examination; existing admissions granted under the residence category in the present cases will not be disturbed.

Court Disposition

Appeal disposed of; residence-based reservation in PG medical courses declared impermissible; institutional preference seats upheld; admissions already granted under the residence category in the present cases not disturbed

Orders

  • Residence/domicile-based reservation in admission to PG medical courses within the State quota is declared unconstitutional and impermissible
  • Institutional preference seats (a reasonable number) are valid; in the present case 32 institutional preference seats upheld