Summary
Candidates who had studied outside Assam challenged the State-quota medical admission requirement of schooling from Classes VII to XII within Assam. The Supreme Court upheld Rule 3(1)(c) of the 2017 rules, including its limited parental-government-posting relaxation, as a reasonable classification connected with local educational opportunities and the State’s need for doctors.
Issues
- Whether Assam’s schooling requirement and limited relaxation for specified parental government postings violated Article 14 in admission to State-quota undergraduate medical and dental seats.
Provisions considered
- Rule 3(1)(c), Medical Colleges and Dental Colleges of Assam (Regulations of Admission into 1st Year MBBS/BDS Courses) Rules, 2017The in-State schooling and qualifying-examination requirement, with relaxation for specified parental postings outside Assam, was upheld as a reasonable eligibility condition for State-quota seats. (¶¶ 2, 16, 32, 33, 34, 35, 36)
- Article 14, Constitution of IndiaThe classification was held intelligible and connected with the objective of serving Assam’s educational and medical needs; the challenged exclusions were not arbitrary. (¶¶ 15, 32, 33, 34, 35, 36)
Held
- Residential and educational requirements may validly govern State-quota admission to basic MBBS/BDS courses. The Court distinguished authorities concerning postgraduate or super-specialty admission, where different considerations applied. (¶¶ 19, 20, 22, 25, 26, 27, 28, 29, 32)
- The relaxation for children studying outside Assam because of specified Assam or Central government-related parental postings did not require identical treatment of children of employees of other States or private employers. The Court accepted the distinction as reasonably connected with likely return to serve Assam. (¶¶ 33, 34)
- Candidates choosing education outside Assam remained eligible to compete for All India quota or open seats; their exclusion was confined to State-quota eligibility. The challenged schooling criterion was not shown to violate Article 14. (¶¶ 35, 36)
Result
Writ petitions and special leave petition dismissed; Rule 3(1)(c) of the 2017 rules upheld. Parties to bear their own costs.