Dr. Tanvi Behl vs. Shrey Goel
Citation: 2025 INSC 125; Supreme Court of India
Background
The case challenged the validity of residence-based (domicile-based) reservation in postgraduate (PG) medical courses at Government Medical College and Hospital, Chandigarh. The college prospectus reserved 64 PG seats in its State quota, with 50% for residents of the Union Territory of Chandigarh and 50% for students with institutional preference (those who completed MBBS at the college). Petitioners, including Dr. Tanvi Behl, argued that this scheme violated the constitutional guarantee of equality and Supreme Court precedents.
Issues
Is residence-based reservation in PG medical courses constitutionally valid under Article 14?
Can State quota seats in PG medical admissions be filled on the basis of domicile/residence?
Supreme Court’s Reasoning
The Supreme Court, comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti, held that residence-based reservation in PG medical courses is unconstitutional and violative of Article 14 (equality before law). The Court relied heavily on the Constitution Bench judgment in Saurabh Chaudri v. Union of India (2003), which distinguished between permissible institutional preference and impermissible residence-based reservation in higher education.
Institutional Preference vs. Residence-Based Reservation:
The Court reiterated that while a reasonable degree of institutional preference (for students who completed MBBS at the same college) is constitutionally valid, reservation solely on the basis of residence or domicile is not. The rationale is that PG medical education is a field of higher learning where the most meritorious candidates should be selected, and residence does not constitute a reasonable classification under Article 14.
Application to Chandigarh Quota:
Of the 64 State quota seats, the 32 filled by institutional preference were upheld as valid. However, the 32 seats reserved for U.T. Chandigarh residents were found to be unconstitutional and must be filled strictly on the basis of merit in the All India examination.
Precedents Cited:
The Court referenced multiple prior judgments, including D.P. Joshi v. State of Madhya Bharat, Jagadish Saran v. Union of India, and Pradeep Jain v. Union of India, all of which stressed the importance of merit and the limited scope for reservation in higher education.
Decision
The Supreme Court struck down the residence-based reservation for PG medical seats in Chandigarh as unconstitutional, upholding only the institutional preference component. All State quota seats, except those validly reserved for institutional preference, must be filled on merit.
Significance
This judgment reaffirms that domicile or residence-based reservations in PG medical courses violate the equality principle and must yield to merit, with only limited institutional preference being permissible under the Constitution.
RELATED Blog
0 comments