The Supreme Court’s Ruling on the Impermissibility of Residence-Based Reservation in PG Medical Courses

1. Introduction

The landmark case of Tanvi Behl v. Shrey Goel (2025 INSC 125) came before the Supreme Court of India with a pivotal constitutional question: whether a State (or Union Territory) can constitutionally establish domicile (or residence) criteria to reserve seats in Postgraduate (PG) Medical Courses. The Appellant, Dr. Tanvi Behl, challenged the constitutionality of residence-based reservations in PG Medical admissions promulgated by the Government Medical College and Hospital, Chandigarh, under the so-called “UT Chandigarh Pool.”

The key issue was whether the allocation of seats exclusively for residents of Chandigarh (or those with academic ties to Chandigarh) violated the principle of equality before the law, thereby infringing Articles 14, 15, and 16 of the Constitution of India. The parties included the Appellant, Dr. Behl, who sought the quashing of the impugned reservation clauses, and the Respondent, Mr. Goel, along with the Chandigargh Administration and other interested parties who defended or were subject to the domicile-based reservation.

By reaffirming and clarifying long-standing constitutional principles, the Supreme Court’s Judgment laid down vital instructions that effectively bar residence-based reservations at the postgraduate level of medical education. This commentary explores the background, rationale, and expansive legal implications of the decision.

2. Summary of the Judgment

The Supreme Court unequivocally held that domicile- or residence-based reservations in PG Medical Courses are impermissible under the Constitution of India. The judges declared such reservation to be in direct conflict with the fundamental demands of equality enshrined in Article 14 of the Constitution. Although institutional preference for postgraduate medical admissions is still permissible to a reasonable extent, any additional requirement that a candidate be a resident of a particular State or Union Territory violates the constitutional guarantee of equality.

The Court therefore answered the first question—whether residence-based reservation in PG Medical courses is permissible—in the negative. Having thus resolved the heart of the matter, the Court did not consider it necessary to examine the subsequent issues about the extent or modality of domicile-based reservation. The Court also clarified that the seats which had been filled under the UT Chandigarh Pool based on domicile (residence) criteria were unconstitutional, but students already admitted under an earlier interim order would not be disturbed.

3. Analysis

3.1 Precedents Cited

The Supreme Court, in this Judgment, relied heavily on three foundational cases that have shaped the judicial view on admissions to higher professional courses:

1. Jagadish Saran v. Union of India (1980) 2 SCC 768 – Although centered primarily on institutional preference, this case recognized that a State or institution can implement limited reservations to ensure fair admission opportunities. However, the Court also recognized that domicile-based preferences compromise merit in higher specialty courses, thus disfavoring broad residency reservations in PG admissions.
2. Dr. Pradeep Jain v. Union of India (1984) 3 SCC 654 – Directly addressed domicile/residence-based reservations for medical courses. The Court distinguished between undergraduate (MBBS) courses, where limited preferential reservations could be permissible to accommodate local and rural needs, and postgraduate (MD/MS) courses, where advanced expertise and merit are at a premium, making domicile-based reservations unconstitutional.
3. Saurabh Chaudri v. Union of India (2003) 11 SCC 146 – A Constitution Bench decision that followed the ratio laid down in Pradeep Jain. In Saurabh Chaudri, the Court explicitly affirmed that for PG Medical admissions, residence-based reservations are impermissible, although institutional preference to a limited extent remains valid.

These precedents collectively underscored that advanced professional education, particularly in the medical field, demands preservation of merit for the public good—a principle squarely at odds with broad-based residential quotas.

3.2 Legal Reasoning

The Court’s reasoning turned on the principle that all citizens of India share a single domicile—the domicile of India. Citing early judgments and constitutional debates, the Court clarified that the word “domicile” in Indian law refers only to the entire territory of India. State-specific or provincial domicile is a misconception and has no support under the Constitution.

The primary constitutional provision relied upon was Article 14 (Right to Equality), complemented by broader interpretations of Article 15 (Prohibition of discrimination on grounds including place of birth) and Article 16 (Prohibition of discrimination in public employment, except by a limited parliamentary power to prescribe residence). The following principles emerged:

• Equality under Article 14: Classifications based on dubious criteria—such as residence—fail to account for the fundamental premise that all Indian citizens are free to move, reside, and seek opportunities across the nation. Such a classification was deemed arbitrary at the postgraduate level, where national expansion of top-tier expertise is essential.
• Distinction between UG and PG Courses: The Court reiterated the stance that States may, to a limited extent, reserve seats in MBBS courses for their residents, given the local needs and the State’s significant investments in undergraduate medical infrastructure. However, in postgraduate and specialized courses, the highest benchmarks of merit must not be diluted. The advanced stages of medical education justify selecting only the best candidates nationwide.
• Single Domicile Principle: The Constitution recognizes only one Indian domicile, rendering State-level domicile requirements incompatible with the overarching principle of equality and single citizenship.

3.3 Impact

The Judgment’s impact is multifold:

• Immediate Effect on Chandigarh Quota: The UT Chandigarh Pool, which had reserved seats for “residents” of Chandigarh at the postgraduate level, was declared unconstitutional. While the Court upheld institutional preference in PG admissions (for students graduating from that same institution), it struck down the residence-based allocation of seats.
• Uniformity Across States and UTs: The Judgment closes the door for States or Union Territories that might have similarly tried to impose residence-based reservations for PG medical seats. Uniform national merit-based admissions in postgraduate medicine stands reinforced.
• No Retrospective Effect: So as not to disrupt ongoing courses, the Court chose not to invalidate admissions already granted under the interim orders. Students admitted through the Chandigarh-based domicile quota in previous years may complete their studies without jeopardy.
• Potential Revisions to State Policies: States will likely revisit or amend their PG medical admissions rules in light of this reassertion that purely residence-based provisions are violative of the Constitution. Practically, this ensures that if any new seat reservation frameworks are implemented, they must align with the principle that advanced professional courses primarily demand merit-based selection.

4. Complex Concepts Simplified

Several constitutional and doctrinal concepts play a crucial role in understanding the Judgment:

1. Domicile vs. Residence: Though often conflated in common usage, “domicile” has a specific technical meaning in law. In India, there is only a single domicile for citizens, covering the entire nation. Being a resident of a particular State for five years does not create a separate “State domicile.”
2. Articles 14, 15, and 16 of the Constitution:
   • Article 14 – Commands that the State shall not deny equality before the law. Any classification, including one based on residence, must have a clear rational nexus with a legitimate objective.
   • Article 15 – Prohibits discrimination on the basis of religion, race, caste, sex, or place of birth. Although “residence” is not mentioned, States must still pass the test of reasonableness under Article 14 when imposing additional criteria.
   • Article 16 – Prohibits discrimination in public employment, including on the ground of residence, unless Parliament enacts a specific law for defined circumstances. While this article directly pertains to jobs rather than educational admissions, it dovetails with the overarching principle of single citizenship for all Indians.
3. Institutional Preference: The Supreme Court allows a limited form of preference wherein medical colleges can prioritize candidates who graduated from that same college’s MBBS program when it comes to PG admissions. This preference is justified where it links to legitimate institutional goals, does not undermine merit significantly, and is not expanded to a broader, constitutionally impermissible “residence” pool.

5. Conclusion

The Tanvi Behl v. Shrey Goel Judgment reinforces and clarifies a consistent line of cases dating back decades. While the Constitution accommodates limited, rational reservations to promote educational access and social justice, the Court draws a clear line at the doorstep of postgraduate education in medicine.

Whereas the State may reasonably provide some preferences at the undergraduate MBBS level—e.g., institutional preferences, moderate seats set aside to address local healthcare deficits—those considerations become overshadowed by the need for strict meritocracy in advanced programs. At the PG level, the nation’s interest in deploying top-tier medical expertise far outweighs a State’s or Union Territory’s interest in favoring its own residents. Allowing such territorial-based classifications ultimately jeopardizes the uniform growth of specialized medical professionals and detracts from the equality principle guaranteed to all citizens under Article 14.

In the broader legal context, this Judgment once again underscores that the unity, integrity, and uniformity of India’s constitutional fabric demands equal treatment of all citizens as one inseparable group. Any localizing requirement in advanced professional education that subverts national merit is constitutionally suspect. Through this Judgment, the Court has effectively reiterated that residence-based reservations have no place in PG Medical admissions and that equality of opportunity and robust national standards of professional excellence must prevail.