No Blanket Institutional Preference in State PG Medical Admissions: Commentary on Dr. Samriddhi Dubey v. State of Chhattisgarh

No Blanket Institutional Preference in State PG Medical Admissions: Commentary on Dr. Samriddhi Dubey v. State of Chhattisgarh

1. Introduction

1.1. Case Overview

This commentary examines the judgment of the Chhattisgarh High Court in Dr. Samriddhi Dubey v. State of Chhattisgarh & Ors., WPC No. 5937 of 2025, decided on 20 November 2025 by a Division Bench comprising the Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru.

The petitioner, Dr. Samriddhi Dubey, a permanent resident of Chhattisgarh who completed her MBBS from a medical college in Tamil Nadu through the All India NEET (UG) counselling, challenged the validity of Rule 11(a) and 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 (“Rules of 2025”). These rules governed the preference in admission to State quota postgraduate (PG) medical seats.

The heart of the dispute was whether the State, through its PG admission rules, could:

  • Give priority in State quota PG seats to candidates who had completed their MBBS from colleges affiliated to Pt. Deendayal Upadhyay Smriti Swasthya Vigyan Evam AYUSH University, Chhattisgarh; and
  • Relegate all other NEET-qualified candidates – including residents of Chhattisgarh with MBBS from outside the State – to a second tier, to be considered only if seats remained vacant.

The petitioner contended that such a scheme:

  • Violated Article 14 of the Constitution (equality before law), and
  • Was contrary to the law declared by the Supreme Court in Dr. TANVI BEHL v. SHREY GOEL & Ors., 2025 SCC OnLine SC 180, which held that residence-based reservation in PG medical courses is impermissible and that State quota PG seats (except for a reasonable quantum of institutional preference) must be filled by merit in the All-India NEET examination.

1.2. Parties

  • Petitioner: Dr. Samriddhi Dubey – a Chhattisgarh domiciliary, MBBS from VMKV Medical College and Hospital, Salem (Tamil Nadu), NEET-PG 2025 All India Rank 75068, registered with both Tamil Nadu and Chhattisgarh Medical Councils.
  • Respondents:
    • State of Chhattisgarh (Health Department), Director Medical Education, and Commissioner, Medical Education – framers and implementers of the Rules of 2025;
    • National Medical Commission (NMC);
    • Director General of Health Services (DGHS), Government of India.

1.3. Core Legal Issues

  1. Whether Rule 11(a) and 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 are:
    • Ultra vires Article 14 of the Constitution; and
    • Contrary to the binding law laid down by the Supreme Court in Dr. Tanvi Behl and earlier constitutional precedents.
  2. Whether the rules, though framed as institutional preference, in effect operate as:
    • A form of blanket institutional reservation monopolising State quota PG seats for local MBBS graduates; and/or
    • A disguised residence/domicile-based preference, forbidden in PG medical admissions.
  3. Whether such a scheme validly promotes legitimate State interests (such as strengthening local health services) or unjustifiably discriminates among equally qualified NEET-PG candidates.

2. Summary of the Judgment

The Chhattisgarh High Court:

  1. Quashed Rule 11(a) and Rule 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, holding them:
    • Ultra vires, and
    • Violative of Article 14 of the Constitution.
  2. Held that the State cannot discriminate between candidates belonging to the categories delineated in Rule 11(a) and (b) for PG admissions in State quota seats.
  3. Expressly grounded its reasoning in the Supreme Court’s decision in Dr. TANVI BEHL v. SHREY GOEL, which reaffirmed that:
    • Residence-based reservations are not permissible in PG medical courses; and
    • State quota PG seats, aside from a reasonable quantum of institutional preference, must be filled on the basis of All-India merit in NEET-PG.
  4. Followed the Madhya Pradesh High Court’s judgment in Sawan Bohra & Anr. v. State of M.P. & Ors., which had invalidated analogous rules in that State.
  5. Allowed the writ petition and issued directions that the State shall not discriminate on the basis of the categories created under Rule 11(a) and (b). No order as to costs was passed.

In essence, the judgment reinforces the principle that merit must prevail in PG medical admissions and that blanket institutional or domicile-based preferences which substantially override merit are unconstitutional.

3. Detailed Analysis

3.1. Statutory and Regulatory Framework

3.1.1. The Parent Act

The Rules of 2025 were framed under the Chhattisgarh Chikitsa Mahavidyalayon Ke Snatkottar Pathykramon Main Pravesh Adhiniyam, 2002 (“Act of 2002”), which empowers the State to regulate admission to postgraduate medical courses.

The State’s rule-making power, however, is subordinate and must comply with:

  • The provisions of the parent statute; and
  • The overarching constraints of the Constitution of India, especially fundamental rights.

3.1.2. From 2021 Rules to 2025 Rules

Earlier, the State had the Chhattisgarh Medical Post Graduate Admission Rules, 2021. Under those rules:

  • Rule 11(a) gave preference in State quota PG seats to:
    • Candidates who obtained MBBS from colleges situated in Chhattisgarh, or
    • In-service candidates.
  • Rule 11(b) provided that if seats remained vacant after considering such candidates, they would be offered to:
    • Candidates who had MBBS from outside Chhattisgarh but were natives of the State.

The petitioner had earlier challenged these provisions in WPC No. 4702/2025. That petition was withdrawn when the State notified new Rules in 2025, with liberty to challenge the new rules.

The Rules of 2025 retained a similar structure in Rule 11:

  • Rule 4 – NRI eligibility;
  • Rule 5 – Ineligibility;
  • Rules 6–8 – Reservations;
  • Rule 9 – Bonus marks for in-service candidates;
  • Rule 10 – Merit list; and
  • Rule 11 – Preferences for admission.

3.1.3. Content of Rule 11 (2025 Rules)

The Court reproduced the relevant Hindi text of Rule 11(a) and 11(b). In substance:

  • Rule 11(a):
    • For seats in the State quota, admissions are to be given first to candidates who:
      • Have obtained MBBS from a medical college affiliated to Pt. Deendayal Upadhyay Smriti Swasthya Vigyan Evam AYUSH University, Chhattisgarh, or
      • Are in-service candidates.
  • Rule 11(b):
    • After all eligible candidates under Rule 11(a) have been admitted, if seats still remain vacant, those seats shall be offered to candidates who have obtained MBBS from other medical colleges (i.e., outside the AYUSH-affiliated system), based on merit.

Effectively, this creates a two-tier system:

  1. First tier: MBBS graduates from AYUSH-affiliated Chhattisgarh colleges and in-service candidates – they get complete priority over all State quota seats.
  2. Second tier: All other NEET-PG qualified MBBS graduates (including those domiciled in Chhattisgarh but who studied outside the State) – considered only if seats remain vacant after the first tier is exhausted.

The petitioner’s specific grievance was that in practice, no seats remained for the second tier. The petitioner asserted that in the previous admission cycle, not a single candidate was admitted under Rule 11(b).

3.2. Factual Matrix and Petitioner’s Position

Key facts about the petitioner:

  • Permanent resident of Chhattisgarh; parents also permanent residents.
  • Completed schooling in Bilaspur, Chhattisgarh.
  • Appeared in NEET-UG 2018 and secured MBBS admission in VMKV Medical College and Hospital, Salem (Tamil Nadu) via All India counselling.
  • Completed MBBS in 2023 and internship in 2024.
  • Registered with both Tamil Nadu and Chhattisgarh Medical Councils.
  • Appeared in NEET-PG 2025, secured All India Rank 75068, and was eligible for PG admission on merit.

Despite being a Chhattisgarh domiciliary and NEET-PG qualifier, the petitioner was effectively placed at a disadvantage solely because she:

  • Did not complete her MBBS from a college affiliated to Chhattisgarh’s AYUSH University; and
  • Therefore fell into the second-tier category of Rule 11(b), where admission would be considered only if seats remained vacant after full allocation to the first-tier group.

3.3. Parties’ Submissions

3.3.1. Petitioner’s Arguments

The petitioner, through Senior Counsel Mr. Rajeev Shrivastava, advanced the following key arguments:

  1. Discriminatory classification (Article 14):
    • Rule 11 divides candidates into two groups:
      1. Those with MBBS from Chhattisgarh medical colleges (AYUSH University affiliates) and in-service doctors; and
      2. Those with MBBS from outside Chhattisgarh.
    • This classification unjustifiably disadvantages candidates like the petitioner, who are residents of Chhattisgarh but studied MBBS elsewhere through legitimate All India counselling.
    • Such a distinction lacks a constitutionally valid basis and violates Article 14.
  2. Rule 11 is effectively a 100% institutional reservation for local MBBS colleges:
    • By giving total priority to AYUSH-affiliated MBBS graduates and in-service candidates for State quota PG seats, Rule 11(a) & (b) create a near-complete monopoly in favour of those institutions.
    • Empirical observation: in the previous year, no candidate was admitted under Rule 11(b), strongly indicating that the “second tier” category was illusory.
  3. Contravention of Supreme Court’s judgment in Dr. Tanvi Behl:
    • The Supreme Court has laid down that:
      • Residence-based reservation in PG medical courses is impermissible;
      • Only a reasonable degree of institutional preference is allowed; and
      • State quota PG seats, beyond such limited institutional preference, must be filled solely on All-India merit in NEET-PG.
    • Rule 11(a) & (b) are in direct conflict with these principles. They virtually convert the entire State quota into an institutional preserve of Chhattisgarh MBBS colleges, which is neither “reasonable” nor permissible.
  4. Residence/domicile element in substance:
    • Although Rule 11 of 2025 does not explicitly refer to “domicile”, its structure and effect disproportionately benefit those who studied MBBS in Chhattisgarh – which, in practice, closely aligns with a residence-based preference.
    • Therefore, it is a disguised form of domicile preference in PG medical admissions, outlawed by the Supreme Court.

3.3.2. State’s Arguments

The State, represented by the Deputy Advocate General, Mr. Shashank Thakur, raised the following defences:

  1. No defect in rule-making power:
    • The criteria for invalidating subordinate legislation include:
      • Lack of legislative competence;
      • Excess of power conferred by the parent Act;
      • Conflict with the parent Act; or
      • Contravention of the Constitution or existing law.
    • The petitioner, it was argued, did not establish any of these grounds, especially in terms of competence or inconsistency with the Act of 2002.
  2. Change from 2021 Rules to 2025 Rules:
    • The 2021 Rules contained explicit domicile-based preferences.
    • Post the Supreme Court’s judgment in Dr. Tanvi Behl, the State consciously removed domicile criteria in the 2025 Rules.
    • Rule 11(b) of 2025 no longer mentions domicile, and thus, the residence-based objection addressed in Tanvi Behl does not apply.
  3. Institutional preference is permissible:
    • There are 10 government and 4 private medical colleges under Pt. Deendayal Upadhyay Memorial Health Sciences and AYUSH University in Chhattisgarh.
    • Admissions (both UG and PG) operate with:
      • 50% seats – All India Quota (counselling by MCC);
      • 50% seats – State Quota (counselling by Directorate / Commissionerate of Medical Education).
    • Within State quota seats, Rule 11(a) only provides institutional preference to:
      • Students from AYUSH-affiliated colleges; and
      • In-service candidates.
    • The Supreme Court in Dr. Tanvi Behl has expressly approved institution-based reservations (to a reasonable extent). Chhattisgarh’s policy should be seen in that light.
  4. Not all preferred candidates are Chhattisgarh residents:
    • Many MBBS students in AYUSH-affiliated colleges are admitted through All India quotas and are residents of other States.
    • Therefore, providing preference to AYUSH college graduates does not amount to domicile/residence reservation for Chhattisgarh natives.
  5. Similarity with M.P. case acknowledged but distinguished on policy:
    • The State fairly accepted that the issue is similar to that decided by the Madhya Pradesh High Court in Sawan Bohra, but defended the Rules of 2025 as a permissible model of institutional preference.

3.3.3. Submissions by NMC and DGHS

Notably, no return was filed and no substantive submissions were advanced on behalf of:

  • National Medical Commission (Respondent No. 4); and
  • DGHS, Government of India (Respondent No. 5).

3.4. The Court’s Legal Reasoning

3.4.1. Centrality of the Supreme Court’s Ruling in Dr. Tanvi Behl

The High Court placed decisive reliance on the Supreme Court’s judgment in Dr. TANVI BEHL v. SHREY GOEL & Ors., 2025 SCC OnLine SC 180, which squarely addressed the question:

“As to whether providing for domicile/residence-based reservation in admission to PG Medical Courses within the State Quota is constitutionally invalid and impermissible?”

After reviewing Pradeep Jain and Saurabh Chaudri, the Supreme Court held:

“Thus, residence-based reservations are not permissible in PG medical courses. … the State quota seats, apart from a reasonable number of institution-based reservations, have to be filled strictly on the basis of merit in the All- India examination.”

The High Court reproduced crucial passages (paras 31–33 of Tanvi Behl), emphasising:

  • We are all domiciled in India and entitled to seek educational opportunities anywhere in the country.
  • While limited reservation on residence grounds may be tolerable at the MBBS level, such a device is unacceptable in PG medical courses due to the critical importance of specialised expertise.
  • A residence-based reservation at the PG level would:
    • Violate Article 14; and
    • Amount to a denial of equality before the law for students from other States.
  • Only a reasonable number of institution-based preference seats is permissible. Beyond that, All-India merit must govern the filling of State quota seats.

The High Court then connected these principles to the Chhattisgarh Rules of 2025, treating them as inconsistent with the law declared by the Supreme Court under Article 141.

3.4.2. The Role of Jagdish Saran and the Primacy of Merit at the PG Level

The Court quoted extensively from Jagdish Saran v. Union of India, where the Supreme Court highlighted:

  • The constitutional guarantee of equality of opportunity – merit-based ranking is central when selecting candidates at higher levels of education.
  • At the postgraduate and super-speciality levels, national interest in high-grade skill and expertise demands that merit not be sacrificed for populist or parochial considerations.
  • Relaxation of standards in these areas is a “grave national risk” and could undermine public welfare.

These observations, reiterated in Saurabh Chaudri, supported the proposition that:

  • Any classification that seriously dilutes merit at the PG level is constitutionally suspect.
  • Reservations or preferences at this level must be minimal, carefully justified, and strictly reasonable.

3.4.3. Following the M.P. High Court in Sawan Bohra

The Division Bench of the Madhya Pradesh High Court in Sawan Bohra & Anr. v. State of M.P. & Ors., WP No. 38169/2025 (decided on 19.11.2025) had recently addressed an identical issue, applying Tanvi Behl to strike down similar PG medical admission provisions that embedded residence-based or excessive institutional preferences.

The Chhattisgarh High Court:

  • Explicitly acknowledged the identity of issues between Sawan Bohra and the present case; and
  • Held that there was no reason to take a different view from the Madhya Pradesh High Court.

This promotes inter-State uniformity in the application of the Supreme Court’s precedents on NEET-based PG admissions.

3.4.4. Ultra Vires and Article 14

In para 21, the Court conclusively declared:

“In view of the proposition of law as laid down by the Apex Court in Dr. Tanvi Behl (supra), Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 are quashed being ultra vires and violative of Article 14 of the Constitution of India, and the State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11(a) and (b)…”

Thus, the invalidity of Rule 11(a) & (b) is based on two inter-related grounds:

  1. Conflict with Article 14: The classification created by Rule 11:
    • Favours one set of NEET-qualified candidates (AYUSH-affiliated MBBS graduates and in-service candidates) over others;
    • Lacks a constitutionally adequate justification at the PG level where merit must dominate; and
    • Leads to unequal treatment of similarly situated candidates based solely on the institution of MBBS study.
  2. Conflict with Supreme Court law under Article 141:
    • Subordinate legislation that violates the law declared by the Supreme Court (here, in Tanvi Behl, Pradeep Jain, Saurabh Chaudri, etc.) is ultra vires the Constitution.
    • The Supreme Court has capped permissible preferences in PG medical admissions to:
      • No residence-based reservation; and
      • Only a reasonable quantum of institutional preference, not a near-total monopoly.

Given the petitioner’s evidence that Rule 11(b) was virtually never triggered in practice, the Court appears to treat the 2025 Rules as:

  • Functionally equivalent to a blanket institution-based reservation for Chhattisgarh MBBS colleges in State quota PG seats, and
  • Thereby inconsistent with the requirement of reasonableness and balance laid down by the Supreme Court.

3.5. Precedents Cited and Their Influence

3.5.1. Pradeep Jain v. Union of India, (1984) 3 SCC 654

Pradeep Jain is the seminal Supreme Court decision on admissions to medical courses. Its core holdings include:

  • Recognising the All-India character of medical education and the need for pan-Indian standards.
  • Permitting limited institutional preference and residence-based reservations at the MBBS level, but:
  • Strongly cautioning against such reservations at the PG level, where merit and national interests in specialised healthcare become paramount.

Subsequent judgments, including Saurabh Chaudri, reaffirmed that while limited preference is tolerated for undergraduate courses, PG courses must largely be merit-based.

3.5.2. Jagdish Saran v. Union of India

Jagdish Saran, quoted in para 18, underpins the modern understanding that:

  • The higher the level of education (particularly in specialised and critical fields like medicine), the higher the requirement of merit.
  • Relaxing standards of admissions at the PG level for reasons of local preference or populism is an unjustified compromise with national development.

The Chhattisgarh High Court drew upon this to emphasise that PG medical education cannot be parochialised without grave risks to professional competence and public health.

3.5.3. Saurabh Chaudri v. Union of India, (2003) 11 SCC 146

This Constitution Bench followed Pradeep Jain and Jagdish Saran and:

  • Endorsed limited institutional preference in PG medical courses under strict scrutiny; and
  • Rejected broad-based regional or domicile preferences for PG seats.

The Chhattisgarh High Court, via Tanvi Behl, relies on this line of authority to hold that:

  • Institutional preference is not an unrestricted tool; and
  • It must not displace the overriding priority of merit in PG admissions.

3.5.4. Magan Mehrotra, Nikhil Himthani, Vishal Goyal, Neil Aurelio Nunes

These decisions, cited via Tanvi Behl, reiterate and fortify the principles from Pradeep Jain:

  • Magan Mehrotra – emphasised adherence to merit and struck down excessive local preferences.
  • Nikhil Himthani and Vishal Goyal – invalidated similar domicile-based or region-based preferences in medical admissions.
  • Neil Aurelio Nunes – while dealing with OBC reservation, reaffirmed the necessity of a constitutional balance between merit and affirmative action, consistent with earlier educational reservation jurisprudence.

3.5.5. Dr. TANVI BEHL v. SHREY GOEL, 2025 SCC OnLine SC 180

This is the contemporary anchor for the present case. It directly answered:

  1. Whether domicile/residence-based reservation in PG medical courses in State quota is permissible (answer: no); and
  2. How State quota PG seats must be distributed between:
    • Institutional preference seats (reasonable in number); and
    • All other seats to be filled purely on All-India NEET merit.

The Supreme Court held that:

  • Residence-based reservations in PG are categorically impermissible.
  • Only a “reasonable number of institution-based reservations” can be provided.
  • All remaining State quota seats must be filled strictly on merit in the All-India NEET examination.

The Chhattisgarh High Court treated these pronouncements as decisive, and any State rule inconsistent with them as void.

3.5.6. Sawan Bohra & Anr. v. State of M.P. & Ors., MP High Court, 19.11.2025

In Sawan Bohra, the Madhya Pradesh High Court:

  • Applied Tanvi Behl to a similar PG admission scheme; and
  • Directed the State to permit candidates to register for counselling and participate without being excluded by unconstitutional domicile/institutional restrictions.

The Chhattisgarh High Court, finding the issues identical, aligned itself with this precedent, promoting coherence across States in the application of the Supreme Court’s medical admission jurisprudence.

3.6. Impact and Implications

3.6.1. For Chhattisgarh’s PG Medical Admission Policy

The direct consequence is that:

  • Rule 11(a) and (b) of the 2025 Rules stand quashed.
  • Chhattisgarh can no longer:
    • Give a near-absolute first right of access to State quota PG seats to AYUSH University MBBS graduates and in-service candidates; nor
    • Push all other candidates, including its own residents who studied MBBS elsewhere, into a residual “if vacant” category.
  • The State must reframe its Rules (or interpret remaining provisions) in a manner that:
    • Respects the primacy of All-India NEET merit for PG admissions; and
    • Limits institutional preferences to a genuinely reasonable proportion with clear, rational justification.

3.6.2. For Other States and Union Territories

Although the judgment is formally binding only within Chhattisgarh, in combination with:

  • The Supreme Court’s decision in Tanvi Behl; and
  • The Madhya Pradesh High Court’s ruling in Sawan Bohra,

it sends a clear signal that:

  • Any State or UT maintaining:
    • Domicile/residence-based reservations in PG medical seats; or
    • De facto blanket institutional reservations that monopolise State quota PG seats;
  • is at serious risk of judicial invalidation of such schemes.

States must therefore promptly audit and rationalise their PG admission rules to:

  • Eliminate residence/domicile criteria at the PG level; and
  • Ensure that institutional preference, if provided, is:
    • Limited in quantum;
    • Reasoned in justification; and
    • Non-exclusionary of meritorious candidates from other institutions.

3.6.3. For Students and Mobility in Medical Education

The judgment protects:

  • Students who, like the petitioner, are residents of a State but pursue MBBS elsewhere through All India admissions.
  • Medical graduates from across India who seek PG seats in other States purely on merit.

It reinforces the idea that:

  • All-India mobility and meritocracy in PG medical education are constitutional norms; and
  • Students should not be penalised for choosing (or being allotted) MBBS seats outside their home State.

3.6.4. For Delegated Legislation and Administrative Compliance

The case is a reminder that:

  • Subordinate legislation (rules, regulations) must continuously conform to evolving Supreme Court jurisprudence.
  • Ignoring or half-implementing the ratio of a binding Supreme Court judgment – such as by merely removing explicit “domicile” clauses while retaining functionally similar institutional monopolies – will not pass judicial scrutiny.
  • High Courts will not hesitate to strike down rules that are:
    • Inconsistent with fundamental rights; or
    • Contrary to law declared by the Supreme Court.

4. Simplifying Key Legal Concepts

4.1. Article 14 – Equality Before Law and Reasonable Classification

Article 14 guarantees:

  • Equality before the law – the State must treat all persons equally; and
  • Equal protection of the laws – like should be treated alike, unlike differently.

However, Article 14 does not forbid all classification; it only forbids arbitrary classification. A valid classification must:

  1. Be based on an intelligible differentia (a clear and reasonable distinguishing factor); and
  2. Have a rational nexus to the objective sought to be achieved.

In this case:

  • The differentia (MBBS from AYUSH-affiliated colleges vs other institutions) was found not to have sufficient rational connection with the legitimate objective at the PG level, given:
    • Binding precedent disallowing residence-based reservation in PG; and
    • The dominance of merit considerations at that higher level.

4.2. Domicile, Residence and Institutional Preference

  • Domicile – A person’s permanent home with intent to reside indefinitely; used in law to distinguish deeper connection than mere residence.
  • Residence – Where a person actually lives; can be temporary.
  • Institutional preference – Giving some advantage in admission to those who have studied in the same institution or under the same university.

The Supreme Court has held:

  • Domicile/residence-based reservations –
    • A limited degree at the MBBS level may be permissible;
    • Not permissible at the PG level in medical education.
  • Institutional preference –
    • May be permitted at PG level, but only to a reasonable extent that does not effectively exclude others or subvert merit.

The problem in this case was that institutional preference, though facially neutral, was applied in a way that it virtually captured all State quota seats for a specific set of institutions, mimicking a domicile/residence reservation in effect.

4.3. State Quota vs All India Quota

  • All India Quota (AIQ):
    • Typically 50% of seats in medical colleges are reserved for AIQ;
    • Admissions are conducted centrally by the Medical Counselling Committee (MCC) based on All-India NEET ranking.
  • State Quota:
    • The remaining seats (50%) are reserved as State quota;
    • Admissions are done by respective State authorities, but must still conform to NEET and constitutional norms.

Even within the State quota, freedom to frame admission policies is not absolute; it is constrained by:

  • NEET as the single entrance test for PG medical courses; and
  • Constitutional limitations, especially those declared by the Supreme Court.

4.4. Ultra Vires and Delegated Legislation

  • Delegated (subordinate) legislation – Rules, regulations, notifications etc. made by the executive under authority granted by a statute.
  • Ultra vires – Literally “beyond powers”; when such rules:
    • Exceed the powers granted by the parent Act; or
    • Contravene the Constitution or binding judicial precedent.

Here, Rule 11(a) & (b) were held ultra vires, not because the State lacked power to make rules, but because:

  • The rules violated Article 14; and
  • Were contrary to the law laid down by the Supreme Court in Tanvi Behl and earlier cases.

4.5. NEET and Merit

  • NEET-PG – National Eligibility-cum-Entrance Test (Post Graduate), conducted as a single national examination for admission to PG medical courses across India (except AIIMS and a few specified institutions).
  • NEET ensures a uniform standard of assessment, enabling:
    • Comparability of candidates nationwide; and
    • Transparent, merit-based admissions both in AIQ and State quota seats.

The Supreme Court’s insistence on merit-based filling of PG seats (beyond limited institutional preference) is anchored in the centrality of NEET as the national benchmark of merit.

5. Conclusion

The judgment in Dr. Samriddhi Dubey v. State of Chhattisgarh consolidates and applies a significant constitutional principle in the domain of medical education:

At the postgraduate level in medical education, merit must prevail; residence-based reservations are impermissible, and even institutional preferences must be limited, reasonable, and cannot operate as a blanket exclusion of other meritorious candidates.

By striking down Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 as ultra vires and violative of Article 14, the High Court:

  • Reaffirms the binding nature of Supreme Court precedents such as Pradeep Jain, Jagdish Saran, Saurabh Chaudri, and particularly Dr. Tanvi Behl;
  • Aligns Chhattisgarh’s legal position with that of Madhya Pradesh (Sawan Bohra), fostering national consistency in PG medical admission norms;
  • Protects the rights of candidates who legitimately choose or are allotted MBBS seats outside their home State; and
  • Sends a clear signal that States must resist parochial temptations to reserve PG seats disproportionately for local institutions or residents.

In the broader legal landscape, this ruling reinforces a crucial balance: while States may legitimately pursue healthcare policy objectives, those objectives cannot be achieved by undermining constitutional equality and the national standard of merit embedded in NEET-PG. The case is thus an important step toward a more uniform, merit-based, and constitutionally compliant framework for postgraduate medical education across India.

Case Details

Year: 2025
Court: Chhattisgarh High Court

Judge(s)

Hon'ble The Chief Justice Hon'ble Shri Justice Bibhu Datta Guru

Advocates

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