Summary
The Court directed Madhya Pradesh to reconsider the 75% residence reservation for B.Ed. admissions in light of persistent vacancies and the limits on wholesale reservation. Residence preference was permissible in principle, but medical-education precedents could not mechanically justify this proportion in a different professional course. The ongoing academic session was left undisturbed, with revision directed for the next year.
Issues
- Whether the 75% residence allocation for B.Ed. admissions was justified by the cited precedents and actual demand.
- What relief was appropriate after the academic session had begun.
Provisions considered
- Article 14, Constitution of IndiaApplied the prohibition on wholesale residence reservation and required reconsideration of the excessive allocation against actual educational conditions. (¶ 14-19)
Held
- Residence-based preference is permissible in principle. However, the State investment, local service and backwardness considerations examined in medical-education precedents required contextual assessment for B.Ed. training rather than automatic transplantation. Contemporary conditions also mattered. (¶ 8-13)
- The undisputed admission figures showed nearly all resident-reserved seats remaining vacant while the outside-State allocation filled. A 75% allocation was too high, amounted to wholesale reservation in the circumstances, and frustrated rather than advanced its purpose. (¶ 14-18)
- Because the 2022-23 session had commenced, the Court refrained from disturbing it. The State was directed to examine prior years’ data, reconsider the allocations for residents and non-residents from the next academic year, and decide within two months. No replacement percentage was itself prescribed by the Court. (¶¶ 18, 19)
Result
Appeal disposed of with directions for reconsideration within two months and revised allocations from the next academic year; the ongoing session was not disturbed.