Context:

The Supreme Court in a significant verdict held that domicile-based reservations for post-graduate medical admissions are unconstitutional and violative of the right to equality. 

Key Highlights of the Judgment

1. Violative of the Right to Equality: 

• The SC held that domicile-based reservation goes against the Right to Equality under Article 14 of the Constitution.
• It held that all Indians have a single domicile—India, and state-based domicile reservations create artificial inequalities among citizens. 

2. No Domicile-Based Reservation in PG Medical Courses:

• The State quota seats must be filled strictly on merit through the All India PG entrance exam. 
• While limited domicile-based reservations may be permissible for MBBS admissions, they are not valid for PG medical courses due to the need for highly skilled specialists. 
• The ruling aligns with Dr. Pradeep Jain vs Union of India case of 1984, which also held that residence-based reservation is impermissible at the PG level.

3. Against National Interest:

• The Court emphasized that doctors must have the freedom to study and practice anywhere in India, ensuring equitable access to specialized medical services across states.

4. Justification for Limited Reservation in MBBS Admissions:

• The Court justified the reservation for MBBS courses considering the state investment in creating medical infrastructure, local needs, and regional backwardness.
• However, such considerations do not apply at the PG level, where medical professionals are highly skilled and are expected to serve the entire nation. 

Implications of the Judgment 

• PG medical admissions will now rely solely on merit determined by the all-India exam, ensuring fairness and equal access for all.
• The ruling eliminates domicile-based reservations, giving students from every state an equal opportunity to secure PG medical seats.
• States will need to adjust their policies to comply with the ruling, removing domicile-based reservation systems.
• Admissions made under the domicile-based reservation system will remain unaffected by this judgment.
• The ruling promotes a merit-based, competitive atmosphere, ensuring equal treatment under Article 14 and potentially improving the overall quality of medical education.

Article 14

Article 14 of the Indian Constitution guarantees the fundamental right of Right to Equality. 

It states that "the State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. 

This means that every individual, regardless of race, religion, gender, or social status, is entitled to equal treatment under the law and has the right to equal protection by the laws of the country.

• Equality Before the Law: This means the law should be applied equally to everyone, treating all individuals in similar situations the same way.
• Equal Protection of the Laws: This suggests that people should receive equal treatment when they are in similar situations or circumstances.
• “The dissent of Justice Subba Rao in the State of U.P. v. Deoman Upadhyaya 1960 stated that Article 14 comprises both “positive content” as well as “negative content”. Whereas, equality before the law is a negative content, equal protection of the laws exhibits a positive content of Article 14.”