Medical PG Admission: Supreme Court Upholds Regulation 9 and Denies In-Service Quota

The Supreme Court of India, in the case of Tamil Nadu Medical Officers Association and Others v. Union of India and Others, addressed a contentious issue regarding medical postgraduate (PG) admissions under Regulation 9 of the Post-Graduate Medical Education Regulations, 2000. The petitioners, primarily in-service government doctors, sought the court’s intervention to allow a separate quota for in-service candidates in PG medical degree courses.

The case was heard by a Constitution Bench consisting of Dipak Misra, A.K. Sikri, A.M. Khanwilkar, D.Y. Chandrachud, and Ashok Bhushan. The court ultimately denied interim relief to the petitioners and upheld the previous ruling in State of Uttar Pradesh v. Dinesh Singh Chauhan, which had held that no separate reservation exists for in-service candidates in PG medical degree courses.

Background of the Case

The case arose due to a dispute over admissions to PG medical courses under Regulation 9 of the Medical Council of India’s (MCI) Post-Graduate Medical Education Regulations, 2000. The Tamil Nadu government had historically provided a 50% reservation for in-service doctors in PG medical degree courses. However, after the amendments to Regulation 9 in 2012, the validity of this reservation was challenged.

The petitioners argued that the state government had the authority under Entry 25 of the Concurrent List to regulate admissions to PG medical courses and provide a separate channel for in-service candidates. They contended that denying them this right would be detrimental to the public healthcare system, as it would disincentivize doctors from serving in rural and remote areas.

Key Legal Issues

• Whether the state government has the authority to provide a separate quota for in-service candidates in PG medical degree courses.
• Whether Regulation 9 of the Post-Graduate Medical Education Regulations, 2000, is a complete code that overrides state policies.
• Whether in-service candidates should be granted reservation in PG medical degree courses.

Arguments Presented

Petitioners’ Arguments

The petitioners argued:

• The state had been implementing an in-service reservation for decades, and withdrawing it would harm the rural healthcare system.
• Entry 25 of the Concurrent List grants the state the power to regulate medical admissions, even if Entry 66 of the Union List gives the central government the power to set standards.
• The court’s decision in Dinesh Singh Chauhan failed to consider important precedents such as R. Chitralekha v. State of Mysore and Modern Dental College and Research Centre v. State of Madhya Pradesh.
• Providing weightage (incentive marks) alone, instead of a separate quota, was insufficient to encourage doctors to serve in rural areas.

Respondents’ Arguments

The respondents, including the Union of India and the Medical Council of India (MCI), countered:

• Entry 66 of the Union List gives Parliament exclusive power to coordinate and determine standards of higher education, overriding state powers under Entry 25.
• Regulation 9 is a complete code governing PG medical admissions, and it allows only for incentive marks, not reservation.
• Any deviation from Regulation 9 would dilute the quality of medical education and compromise merit.
• The court in Dinesh Singh Chauhan had already settled the issue by ruling that in-service candidates were not entitled to a separate quota.

Supreme Court’s Observations

The Supreme Court extensively analyzed Regulation 9 and the constitutional provisions governing medical education. It held:

“The judgment in Dinesh Singh Chauhan has not considered the entries in the legislative lists of the Seventh Schedule, more particularly Entry 66 of the Union List and Entry 25 of the Concurrent List.”

However, the bench reaffirmed that Entry 66 of the Union List gives the central government overriding authority in setting standards for medical education.

The court also observed:

“Regulation 9 is a self-contained code regarding the procedure to be followed for admissions to medical courses. The procedure for selection of candidates for the postgraduate degree courses is one such area on which the Central legislation and regulations must prevail.”

Regarding incentive marks for in-service candidates, the court clarified:

“The proviso to Regulation 9(IV) does not provide for reservation for in-service candidates but only for giving a weightage in the form of incentive marks.”

Final Judgment

The Supreme Court denied the petitioners’ request for interim relief and upheld the ruling in Dinesh Singh Chauhan. It concluded:

“We are unable to accede to the prayer for interim relief. The grant of any interim relief at this stage would amount to a mandatory final order which cannot be countenanced.”

Implications of the Judgment

• State governments cannot introduce a separate quota for in-service candidates in PG medical degree courses.
• Medical PG admissions will continue to follow Regulation 9, which provides incentive marks rather than reservation for in-service candidates.
• Doctors working in rural areas will only receive weightage (extra marks) in PG entrance exams rather than a guaranteed seat.
• The ruling strengthens the principle that the central government’s role in setting standards for medical education takes precedence over state policies.

This decision reinforces the primacy of merit-based selection in medical education and ensures uniformity in admissions across the country.

Petitioner Name: Tamil Nadu Medical Officers Association and Others.
Respondent Name: Union of India and Others.
Judgment By: Justice Dipak Misra, Justice A.K. Sikri, Justice A.M. Khanwilkar, Justice D.Y. Chandrachud, Justice Ashok Bhushan.
Place Of Incident: Tamil Nadu.
Judgment Date: 24-04-2018.

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