Maharashtra Domicile Rule for PG Medical Admissions Struck Down by Supreme Court

The Supreme Court of India, in the case of State of Maharashtra and Others v. Dr. Sharvil Thatte and Others, ruled against the domicile-based eligibility criteria for postgraduate (PG) medical and dental admissions in private educational institutions in Maharashtra. The ruling reaffirmed that while institutional preference is allowed, domicile-based reservations for PG medical seats violate the principles of merit-based admissions.

The judgment, delivered by a bench comprising Arun Mishra and Uday Umesh Lalit, upheld the Bombay High Court’s decision that struck down the domicile requirement for PG medical admissions in unaided private medical colleges.

Background of the Case

The case arose from a notification issued by the Maharashtra government on January 30, 2018, which specified eligibility criteria for PG medical and dental courses. Clause (ii) of the notification mandated that candidates must be domiciled in Maharashtra to qualify for admission in unaided private medical institutions.

The respondents, who were aspiring PG medical students, challenged the notification in the Bombay High Court, arguing that such a domicile condition violated their right to equal opportunity and contradicted Supreme Court rulings that emphasized merit-based admissions for PG medical courses.

Key Legal Issues

• Whether the Maharashtra government’s domicile requirement for PG medical admissions violated constitutional provisions.
• Whether the Supreme Court’s previous rulings on merit-based PG medical admissions were applicable to unaided private medical institutions.
• Whether the state government had the authority to impose such domicile-based restrictions under the Medical Council of India (MCI) regulations.

Arguments Presented

Petitioners’ Arguments (State of Maharashtra)

The Maharashtra government defended its domicile requirement, arguing:

• The rule was necessary to ensure that local students had better access to medical education and would contribute to the state’s healthcare system.
• Several other states had implemented similar domicile-based reservations.
• The policy was intended to retain medical talent within Maharashtra and address the shortage of doctors in rural areas.
• The provision only applied to private unaided institutions, which should have some discretion in admission policies.

Respondents’ Arguments (Dr. Sharvil Thatte & Others)

The aspiring PG medical students argued:

• The domicile requirement was unconstitutional and violated Article 14 (Right to Equality) of the Indian Constitution.
• The Supreme Court had already ruled against such domicile-based restrictions in Dr. Pradeep Jain v. Union of India and Vishal Goyal v. State of Karnataka.
• The Medical Council of India (MCI) regulations mandated that admissions be based on merit, and state governments could not override this with domicile-based reservations.
• The Bombay High Court had previously stayed a similar provision for the 2017-18 academic year, and the state government’s attempt to reintroduce it was unjustified.

Supreme Court’s Observations

The Supreme Court upheld the High Court’s decision, declaring the domicile rule unconstitutional. The Court made the following key observations:

Domicile-Based Reservation Not Allowed for PG Medical Admissions

The Court emphasized that while institutional preference is permitted, domicile-based reservations for PG medical courses are unconstitutional:

“Though it will be permissible to provide reservation on the ground of institutional preference, the condition that requires a candidate who has already obtained a graduate degree to be domiciled in that state is impermissible.”

Previous Supreme Court Rulings Must Be Followed

The Court reiterated its stance in Dr. Pradeep Jain v. Union of India and Vishal Goyal v. State of Karnataka, stating:

“We have accepted the challenge to similar conditions imposed by the State of Karnataka in our judgment dated 04.04.2018. In light of established precedents, we affirm the High Court’s decision in striking down Maharashtra’s domicile requirement.”

Maharashtra’s Policy Was Unconstitutional

The Court ruled that the domicile requirement violated constitutional provisions:

“The High Court rightly held that such a condition would restrict the principle of merit-based selection and is contrary to the Medical Council of India (MCI) regulations.”

Final Judgment

The Supreme Court dismissed the appeal by the Maharashtra government and upheld the Bombay High Court’s ruling:

• The domicile requirement for PG medical admissions in Maharashtra was struck down.
• The admissions for the academic year 2018-19 were to be conducted purely on merit, without domicile-based restrictions.
• The Maharashtra government was directed to implement a merit-based selection process in compliance with MCI regulations.

Implications of the Judgment

• This ruling reinforces the principle that merit should be the sole criterion for PG medical admissions.
• It prevents state governments from imposing unconstitutional domicile-based restrictions.
• The judgment ensures that students from other states who complete their MBBS in Maharashtra are treated equally in PG admissions.
• The ruling may prompt other states to reconsider similar domicile-based rules.
• It strengthens the role of MCI regulations in maintaining uniformity in medical education across India.

This landmark judgment ensures that PG medical admissions remain based on merit and prevents arbitrary state-level restrictions that could hinder students’ career prospects.

Petitioner Name: State of Maharashtra and Others.
Respondent Name: Dr. Sharvil Thatte and Others.
Judgment By: Justice Arun Mishra, Justice Uday Umesh Lalit.
Place Of Incident: Maharashtra.
Judgment Date: 05-04-2018.

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