Supreme Court Strikes Down Karnataka's Domicile Rule for Medical PG Admissions

The Supreme Court of India, in the case of Dr. Kriti Lakhina & Others v. State of Karnataka & Others, struck down Karnataka’s domicile-based eligibility rule for Postgraduate (PG) medical and dental admissions. The petitioners, a group of 44 doctors, challenged Clause 4 of the Information Bulletin issued by the Karnataka government, which restricted government quota seats to candidates of Karnataka origin.

The judgment, delivered by a bench comprising Uday Umesh Lalit and Arun Mishra, held that such domicile-based reservations violated Article 14 of the Constitution and were contrary to previous Supreme Court rulings that emphasized merit-based admissions for PG medical courses.

Background of the Case

The dispute arose from Karnataka’s Information Bulletin, issued jointly by the Directorate of Medical Education and Karnataka Examinations Authority, for PG medical and dental admissions. Clause 4 of the bulletin imposed domicile requirements, stating that only candidates of Karnataka origin could compete for government seats.

The petitioners, who had completed their MBBS/BDS in Karnataka but were not of Karnataka origin, argued that the clause unfairly excluded them from competing for government quota seats, despite their high ranks in NEET-PG.

Key Legal Issues

Whether Karnataka’s domicile-based eligibility criteria for PG medical admissions were constitutional.
Whether the state government had the authority to impose such restrictions under the Medical Council of India (MCI) regulations.
Whether the rule was discriminatory and violated Article 14 of the Constitution.

Arguments Presented

Petitioners’ Arguments

The petitioners, represented by Senior Advocate Amrendra Sharan, argued:

The domicile rule arbitrarily deprived non-Karnataka-origin students who had completed their MBBS in Karnataka from competing for government quota PG seats.
The Supreme Court in Vishal Goyal v. State of Karnataka had already struck down a similar provision in 2014.
The rule was against the principle of merit-based selection as established in Dr. Pradeep Jain v. Union of India and other cases.
The Medical Council of India’s (MCI) regulations did not allow such domicile-based restrictions for PG medical admissions.

State of Karnataka’s Arguments

The State of Karnataka, represented by Senior Advocate Basavaprabhu S. Patil, defended the rule, arguing:

The rule was designed to ensure that PG medical seats were available for Karnataka-origin candidates who would serve in the state’s healthcare system.
The state had a shortage of doctors in government hospitals, and restricting PG admissions to Karnataka-origin students would help retain medical talent within the state.
The MCI regulations did not explicitly prohibit such domicile requirements.
Similar policies were followed in other states.

Supreme Court’s Observations

The Supreme Court examined the constitutionality of the domicile rule and referred to previous judgments on the issue. The bench made the following key observations:

“Clause 4.1 of the Information Bulletin in question was violative of Article 14 of the Constitution and was opposed to Regulation 9 of the Medical Council of India (MCI) Regulations.”

The Court cited its ruling in Vishal Goyal v. State of Karnataka, where a similar domicile rule was declared unconstitutional:

“Institutional preference for PG admissions is permissible up to 50%, but domicile-based reservations cannot be imposed by the state. The rule arbitrarily excludes students who have studied in Karnataka but are not of Karnataka origin, violating the principle of equality.”

Key Excerpts from the Judgment

The Court reiterated that PG medical admissions should be merit-based, stating:
“Excellence cannot be compromised at the PG level. Domicile-based reservations for PG courses are not permissible under Article 14.”
Regarding the MCI’s stance on domicile reservations, the Court noted:
“The MCI regulations do not allow states to impose domicile-based restrictions for PG admissions. Institutional preference is allowed but cannot be extended to domicile-based selection.”
On Karnataka’s justification that the rule was needed to retain doctors in the state:
“The state’s argument that such a rule is necessary to ensure doctors serve in Karnataka is not legally sustainable. Service bonds and incentives are legitimate ways to retain doctors, but domicile restrictions violate constitutional principles.”

Final Judgment

The Supreme Court struck down Clause 4.1 of the Information Bulletin and directed Karnataka to modify its admission criteria:

The domicile requirement for government quota PG medical seats was declared unconstitutional.
The Karnataka government was ordered to amend the Information Bulletin and conduct admissions based on NEET-PG merit rankings.
The ruling was made applicable to all similarly situated candidates.
The admission process had to be completed within the timeline set by regulatory authorities.

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 domicile-based restrictions that violate constitutional rights.
The judgment ensures that all students who complete MBBS in a state are treated equally in PG admissions, regardless of their state of origin.
The ruling may prompt other states to reconsider similar domicile-based rules for medical admissions.
It strengthens the role of MCI regulations in maintaining uniformity in medical education across India.

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

Petitioner Name: Dr. Kriti Lakhina & Others.
Respondent Name: State of Karnataka & Others.
Judgment By: Justice Uday Umesh Lalit, Justice Arun Mishra.
Place Of Incident: Karnataka.
Judgment Date: 04-04-2018.

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