Summary
The Court referred to a larger Bench the constitutional permissibility of domicile or residence-based reservation in State-quota postgraduate medical admissions and the consequences of either answer. It identified unresolved questions about the interaction of precedents, NEET merit and a Union Territory having only one medical college. The validity of Chandigarh’s particular eligibility clauses was left open, and existing interim orders continued.
Issues
- Whether domicile or residence-based reservation in State-quota postgraduate medical admissions was constitutionally permissible.
- If permissible, what extent and modalities should apply, particularly where there was only one medical college.
- If impermissible, how seats outside permissible institutional preference should be filled.
Held
- The recurring issue required authoritative reconciliation of the decisions on residence-based reservation with the Constitution Bench discussion in Saurabh Chaudri. The Court considered that institutional preference and residence-based preference required distinct analysis. (¶¶ 15, 16, 17, 18, 19, 20)
- Admissions within any quota or preference remained based on NEET merit. The effect of a blanket prohibition on State-quota allocation, especially in a Union Territory with one college, raised further questions requiring examination. (¶¶ 21, 22, 23)
- Even if residence-based reservation were permissible, Chandigarh’s particular requirements still raised questions of rationality. Their final validity was left open pending answers to the root constitutional questions. (¶¶ 20.5, 24)
- The permissibility question, extent and manner if valid, special modalities for a single-college State or Union Territory, and allocation if invalid were referred to a larger Bench. Existing interim orders were to continue until further orders. (¶¶ 25, 26, 27)
Result
Matters referred to the Chief Justice of India for constitution of an appropriate larger Bench. The constitutional questions and validity of the specific Chandigarh clauses were not finally decided. Existing interim orders continued until further orders.