Bilaspur: The Chhattisgarh High Court has struck down Rule 11(a) and 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, terming them discriminatory, unconstitutional and violative of Article 14. These rules gave priority in PG medical admissions to candidates who completed MBBS within the state, placing others—despite being natives of Chhattisgarh—at a disadvantage.
Court Stresses Merit Over Institutional Preference
The division bench of Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru observed that merit must prevail in admissions to specialised medical courses. The judges noted that diluting merit under the guise of institutional or domicile preference could compromise the quality of specialised medical education, which demands the highest level of professional competence.
Why the Rules Were Deemed Discriminatory
Rule 11(a) prioritised state-quota seats for candidates who completed MBBS in Chhattisgarh or were in service within the state. Rule 11(b) allowed only leftover seats for students who completed MBBS outside the state but belonged to Chhattisgarh. The bench held that this classification unfairly divided similarly placed candidates and violated the constitutional mandate of equal treatment.
Petitioner Challenges State’s Admission Framework
The court was hearing a petition filed by Dr Samriddhi Dubey, a native of Bilaspur who completed her MBBS from Tamil Nadu and qualified NEET-PG 2025. She argued that despite being a Chhattisgarh resident, she was placed in a lower priority category solely because her MBBS was from outside the state—a classification she claimed had no rational basis.
Arguments on Constitutional Validity
Dr Dubey submitted that the rules created an arbitrary and unjustifiable distinction amounting to institutional reservation, which the Supreme Court had already disapproved in similar matters. She contended that grouping candidates based on the location of their MBBS degree violated Article 14, as it was neither reasonable nor backed by legitimate state interest.
State Defends Rules, Claims No Discrimination
The Chhattisgarh government argued that the petitioner lacked grounds to challenge the 2025 rules. It maintained that the rules did not grant domicile preference and were framed strictly for state-quota seats. The state also claimed that institutional preference under Rule 11(a) did not necessarily correlate with domicile status and therefore did not amount to discrimination.
Supreme Court and Other High Court Precedents Considered
The court referred to the Supreme Court’s ruling in Dr Tanvi Behl, which held that domicile-based reservation in PG medical admissions is unconstitutional. It also noted that the Madhya Pradesh High Court had struck down similar provisions and allowed affected students to participate in counselling. As the circumstances were identical, the Chhattisgarh High Court followed the same reasoning.
Rules Declared Unconstitutional; Equal Opportunity Directed
Concluding that the rules violated Article 14, the bench declared Rule 11(a) and 11(b) of the Chhattisgarh PG Medical Admission Rules, 2025 ultra vires and unconstitutional. The court directed the state to ensure that no discrimination occurs between candidates based on the location of their MBBS degree, reaffirming that merit should be the sole criterion for PG medical admissions.
