Summary
The Supreme Court invalidated Madhya Pradesh’s rule excluding seats vacated after mop-up allotment from college-level medical counselling. Preventing manipulation and preserving merit were legitimate aims, but leaving recognized seats empty lacked the necessary connection and imposed an excessive restriction on colleges. Existing sanctions addressed defaulting candidates. The appeals were allowed, with directions to fill seven vacant first-year MBBS seats for 2020–21 through college-level counselling within seven days of the operative order.
Issues
- Whether excluding seats vacated through nonjoining or resignation after mop-up allotment from college-level counselling violated equality and occupational freedom.
Provisions considered
- Rule 12(8)(a), Madhya Pradesh Chikitsa Shiksha Pravesh Niyam, 2018The exclusion of these vacant seats from subsequent college-level counselling was struck down as lacking rational connection to the object and imposing a disproportionate restriction. (¶¶ 1, 5, 11, 23, 24, 25, 26)
- Articles 14 and 19(1)(g), Constitution of IndiaApplying rational nexus and proportionality review, the Court found the rule arbitrary and excessively restrictive of the institutional right to admit students, while recognizing legitimate regulation of merit and transparency. (¶¶ 12, 13, 15, 17, 18, 19, 20, 21, 24, 25)
Held
- Managing an educational institution is a protected occupation encompassing admission of students, subject to regulation securing merit, fairness and transparency. The validity of the wider admission framework was not in issue. (¶¶ 12, 13, 14)
- Although preventing seat-blocking and manipulation was legitimate, the rules already penalized defaulting candidates through forfeiture and exclusion. Penalizing institutions by forcing seats to remain vacant was excessive on the framework considered. (¶¶ 11, 23, 24)
- Leaving recognized medical seats unfilled caused financial loss and wasted national resources. The distinction based on nonjoining vacancies did not have a rational connection with the stated object, and the restriction failed proportionality. (¶¶ 24, 25)
- The operative order directed college-level counselling for seven first-year MBBS vacancies for 2020–21 within seven days; the subsequent reasons explained the invalidation of Rule 12(8)(a). (¶¶ 1, 2, 26)
Result
Appeals allowed; the High Court judgment set aside and Rule 12(8)(a) invalidated under Articles 14 and 19(1)(g), with the earlier operative admission directions maintained.