Context:
In Dr. Tanvi Behl vs. Shrey Goyal (2025), the Supreme Court struck down domicile based reservations for post graduate medical admissions. The ruling held that State specific quotas are unconstitutional under Article 14 (Right to Equality), claiming that merit should prevail over the State’s right to decide.
Article 14 (Right to Equality)
The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India, on grounds of religion, race, caste, sex or place of birth.
Impact on State Health Planning
Loss of Medical Workforce Stability
- Domicile quotas ensure that trained doctors remain in their States, which are being used to address many chronic specialist shortages.
- The post graduate education case is the primary case for qualification for medical specialist education, as MBBS degree programs are mainly for general training.
- The absence of reservations means that States will invariably have to look at external recruitment, which is unreliable and inefficient.
Erosion of Competitive Federalism
- States invest enormous funds into medical colleges, while expecting these graduates would help serve the states’ healthcare systems.
- The moment the states feel secure about the local specialist workforce, they may downgrade their financial commitment into medical education, and this will worsen their healthcare infrastructure.
- Central institutions such as AIIMS, PGIMER, JIPMER enjoy selection autonomy, while State run medical colleges are denied the same creating an unfair disadvantage.
Implications for Public Health & the Constitution
- Article 21 (Right to Life) denotes access to healthcare, making medical education more of a public health issue than an academic one.
- State medical colleges are not merely institutions of institutional learning but vital links in the public healthcare system.
- The health sector, centralised beyond reason, confisei States of autonomy, and in return, deny them the adjustments necessary for dealing with local health care needs.
Absolute Meritocracy Is a Fallacy
Flaws of NEET PG
- Meritocracy is not absolute: entrance tests do not provide full consideration of regional disparities and socio economic barriers.
- Any inconsistencies in merit assessment were exposed in 2023 when the NEET PG qualifying percentile was brought down to zero by the National Medical Commission (NMC) for filling vacant seats.
- If regional and socio economic factors were to be taken into account in undergraduate admissions, how could post graduate admissions be exempt?
Court Interpretations on Merit & Equity
- Earlier Supreme Court cases(Jagdish Saran (1982), Pradeep Jain (1984), Neil Aurelio Nunes (2022), Om Rathod (2024))have ruled that:
- Merit must be defined in a social context.
- What matters are public service outcomes and not exam results.
- Domicile quotas would ensure that communities get access to healthcare services, in the context of social justice.
Source: TH
