Supreme Court Ruling on Domicile-Based Reservations in Medical Education

The Supreme Court's recent ruling in the case of Dr. Tanvi Behl vs Shrey Goyal (2025) marks a substantial transformation in India's medical education policy by striking down domicile-based reservations in post-graduate medical admissions on the grounds of violating Article 14 of the Constitution. This decision disrupts a long-standing mechanism used by states to ensure a consistent medical workforce tailored to their public health requirements.

Impact on State Medical Workforce

• Domicile Quotas:
  • Were critical in aligning state investment in medical education with healthcare personnel retention.
  • Provided a predictable supply of doctors familiar with the state's healthcare landscape.
• Specialist Workforce:
  • Post-graduate courses were essential for states to replenish their specialist workforce.
  • Striking down quotas may force states to rely on external recruitment, which can be unpredictable and inefficient.

Challenges for State Investment

• Incentives for Investment:
  • Without domicile quotas, states may lack motivation to invest in medical education, leading to infrastructural decline and regional healthcare disparities.
• State Autonomy:
  • Unlike central institutions like AIIMS, state medical colleges lack similar autonomy, impacting long-term healthcare planning.

Constitutional and Public Health Perspectives

• Article 21:
  • Guarantees the right to life, which includes access to adequate healthcare, emphasizing the role of medical colleges in state health infrastructure.
• Centralization Concerns:
  • Excessive centralization through court rulings may limit states from developing policies tailored to their public health needs.

Meritocracy and Equity in Medical Admissions

• Merit Assessment Issues:
  • The NEET-PG results highlight flaws in the merit assessment process, such as candidates qualifying with negative scores due to percentile-based cutoffs.
• Socio-Economic Considerations:
  • Judgments on medical education emphasize that administrative efficiency should consider societal good and structural inequalities.

Alternative Approaches and Policy Considerations

• Integrated Frameworks:
  • Proposes linking quotas with public service obligations as practiced in Tamil Nadu, ensuring state investment results in direct healthcare benefits.
• Judicial and Policy Reevaluation:
  • A balanced approach is necessary to retain state autonomy in structuring medical education policies in line with healthcare priorities.

The ruling highlights a need for evolving judicial doctrines to better accommodate the interplay between medical education, federalism, and public health policy, ensuring a robust and sustainable healthcare system in India.