The Punjab and Haryana High Court has upheld the Haryana Government’s September 2024 policy allowing all in-service government doctors to apply for admission to MD/MS courses under the 40% in-service quota, even if they have not completed two years of service in rural or remote areas. The Court held that the State has the authority to prescribe eligibility conditions for admissions under the in-service quota and that the policy is aimed at strengthening healthcare services in rural and difficult areas.
Challenge to the Policy Rejected
The Haryana Government’s September 2024 policy permits all in-service government doctors to apply for postgraduate medical admissions under the 40% in-service quota, irrespective of whether they have completed two years of service in rural or remote areas.
A group of doctors challenged the policy, arguing that only those who had completed the mandatory rural, remote, or difficult area service should be eligible to compete under the in-service quota for MD/MS admissions.
Rejecting the challenge, the High Court held that the State is competent to create a separate admission channel for in-service doctors and determine the eligibility criteria governing such admissions.
Court Upholds State’s Objective
The Court observed that the policy seeks to enable government-employed MBBS doctors to obtain postgraduate qualifications so that they can provide improved specialist healthcare services, particularly in rural and difficult areas.
The Bench noted that the policy requires in-service doctors who have not completed rural service to execute a bond undertaking to serve the State Government for a minimum of five years in rural, remote, or difficult areas after acquiring their postgraduate qualification.
According to the Court, this condition adequately advances the policy’s objective of strengthening healthcare delivery in underserved regions.
Different Treatment for Two Categories of Doctors Found Valid
The High Court also examined the distinction made between two categories of in-service doctors under the policy.
Doctors who have already completed two years of service in rural, remote, or difficult areas are permitted to pursue postgraduate studies while continuing to receive their salary and other service benefits. In contrast, doctors who have not completed the required rural service are allowed to pursue postgraduate education without salary, although their continuity of service is maintained.
The Court held that this classification is based on an intelligible differentia and bears a direct nexus with the objective of encouraging service in rural and difficult areas while improving the availability of specialist doctors.
Court Refers to Earlier Government Notification
The Bench also referred to the Haryana Government’s January 2018 notification, under which 46 blocks across various districts were identified as remote or difficult areas for providing incentives and other benefits to government doctors.
The Court found no constitutional infirmity, manifest arbitrariness, or illegality in the September 2024 policy and dismissed the challenge to its validity.
Important Highlights
- The Punjab and Haryana High Court has upheld Haryana’s September 2024 policy on the 40% in-service quota for MD/MS admissions.
- The policy allows all in-service government doctors to apply, even without completing two years of rural or remote service.
- Doctors who have not completed rural service must execute a bond to serve for five years in rural, remote, or difficult areas after completing their postgraduate course.
- The Court held that the State has the authority to prescribe eligibility conditions for admissions under the in-service quota.
- The Bench ruled that the distinction between doctors who have completed rural service and those who have not is legally valid and supports the policy’s objective.
