January 29, 2025: The Supreme Court of India on Wednesday ruled that domicile-based reservations for postgraduate (PG) medical admissions are unconstitutional, deeming them a violation of Article 14 of the Constitution. The judgment holds that admissions under state quotas in PG medical courses must be based solely on merit, as determined by the National Eligibility cum Entrance Test (NEET).

The three-judge bench, comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti, firmly stated that residence-based reservations are incompatible with the constitutional right to equality. The court noted that, according to Article 19, every citizen has the right to reside, trade, and pursue a profession anywhere in India, emphasizing that the concept of domicile does not apply at the national level.

“We are all domiciles in the territory of India. There is nothing like a provincial or state domicile. There is only one domicile. We are all residents of India,” the bench declared.

This landmark ruling underscores the importance of merit-based selection for PG medical programs, especially as these courses focus on specialized medical knowledge and expertise. The court observed that extending domicile-based reservations to postgraduate courses would violate the constitutional guarantee of equality.

While acknowledging that some form of domicile-based reservation could be acceptable at the undergraduate (MBBS) level, the bench made it clear that such reservations cannot extend to PG medical courses. “Considering the importance of specialised doctors in PG medical courses, reservation in higher levels on the basis of residence would be violative of Article 14 of the Constitution,” Justice Dhulia read from the judgment.

The court clarified that this ruling would not affect students already enrolled or who have completed their PG medical education under domicile-based reservation policies. “This judgment will not affect the domicile reservation already granted. Students who are undergoing PG courses and those who have already passed out from such residence category will not be affected,” the bench stated.

The matter had previously been brought before the Supreme Court in 2019 when a two-judge bench had dealt with appeals against a Punjab and Haryana High Court ruling that declared domicile-based reservations unconstitutional. Recognizing the significance of the issue, particularly in Chandigarh, where only one medical college exists, the bench referred the case to a larger bench. The current ruling has now provided clarity, ensuring that PG medical admissions will be determined on merit and not restricted by domicile-based criteria.