Chennai: The Madras High Court has ruled that linguistic minority self-financing medical colleges are required to adhere to the National Medical Commission’s (NMC) regulation mandating a 50% seat-sharing arrangement for postgraduate (PG) medical courses. This rule, as outlined in the Post Graduate Medical Education Regulations (PGMER) 2000, requires medical colleges to allocate half of their PG seats to the State or Union Territory to enable effective implementation of reservation policies.
Justice Vivek Kumar Singh emphasized that state or union territory control over a portion of PG seats is crucial for enforcing reservation policies comprehensively. The court highlighted that such seat-sharing arrangements are indispensable for ensuring the benefits of reservation policies are fully realized.
“The reservation benefits must be implemented in their entirety. States and Union Territories cannot effectively enforce social reservations without controlling a portion of the seats,” the court stated. “Seat-sharing is therefore a sine qua non for the successful implementation of reservation policies.”
The judgment arose from a petition filed by Sri Venkateshwaraa Medical College Hospital and Research Centre, challenging an order by the Directorate of Health and Family Welfare Services, Puducherry, which required the college to allocate 50% of its sanctioned PG seats to the government quota for the academic year 2024-25.
Arguments by the Petitioner
The college contended that enforcing the seat-sharing rule amounted to “nationalization” of seats. It argued that the 2000 regulations, which mandated this provision, had been replaced by the 2023 PGMER, which did not explicitly mention seat-sharing. The institution further cited Clause 4.8 of the 2023 regulations, claiming that reservation policies should align with applicable state laws. The college argued that under the 2006 Puducherry regulations, linguistic minority institutions were exempt from reservation policies, and all its PG seats should be treated as management quota seats.
Counterarguments by the Government and NMC
Government representatives and the NMC opposed the college’s plea, asserting that seat-sharing is essential for implementing reservation policies and ensuring fair access to education. They accused the institution of prioritizing profit over legal obligations.
Court’s Findings
The court acknowledged that while the 2023 regulations lack an explicit seat-sharing clause, they uphold the broader principle of extending reservation benefits to eligible candidates. The court further determined that the 2006 Puducherry regulation exempting linguistic minority institutions from reservation policies conflicts with central laws and the 2023 PGMER. Consequently, the central regulations take precedence.
“The term ‘Medical Colleges/Institutions’ in Clause 4.8 of PGMER includes minority institutions, thereby mandating the application of reservation policies to all medical colleges, including minority institutions,” the court observed.
It also noted that treating all PG seats as management quota seats, as argued by the petitioner, would harm the interests of linguistic minority candidates.
Conclusion
The court dismissed the petition, concluding that the petitioner’s claims were inconsistent with legal provisions. It reaffirmed the applicability of NMC regulations to all medical colleges, including linguistic minority institutions, ensuring that reservation policies are implemented effectively.
