Chhattisgarh HC Quashes PG Medical Admission Rules for Violating Article 14, Rejects Institutional/Domicile Preference, Upholds Merit [Read Order]

BILASPUR: In a significant judgment delivered on November 20, 2025, the High Court of Chhattisgarh at Bilaspur, comprising Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru, quashed Rule 11(a) and Rule 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, declaring them ultra vires and violative of Article 14 of the Constitution of India. The ruling came in Dr. Samriddhi Dubey D/o Shri Sandeep Dubey v. State of Chhattisgarh & Others.

The petitioner, Dr. Samriddhi Dubey, who completed her MBBS from VMKV Medical College and Hospital, Salem, and qualified NEET (PG)-2025, challenged the rules on the ground that they created an unjustifiable classification among candidates. Her counsel, Mr. Rajeev Shrivastava, Senior Advocate, submitted that the rules effectively granted 100% reservation to candidates who obtained their MBBS degree from a medical college affiliated with Pt. Deendayal Upadhyay Smriti Swasthya Vigyan Evam Ayush University, Chhattisgarh, or to in-service candidates. He argued that the rules—similar to the previously challenged 2021 Rules—amounted to “university-based reservation,” violating Article 14 because they created an unjustifiable distinction between residents of the State and all others. Mr. Shrivastava further pointed out that the 2025 Rules were substantially similar to the 2021 Rules and again resulted in 100% reservation for candidates who obtained degrees from Chhattisgarh institutions.

The State, represented by Mr. Shashank Thakur, Deputy Advocate General, contended that the 2025 Rules had removed domicile-based preference and instead provided institutional preference under Rule 11(a) to candidates who completed their MBBS from colleges affiliated to AYUSH University. He relied on the Supreme Court decision in Dr. Tanvi Behl v. Shrey Goel & Others, submitting that “institution-based reservations have been approved.”

However, the High Court, after considering the submissions, relied extensively on the principles laid down by the Supreme Court in Dr. Tanvi Behl (2025 SCC OnLine SC 180). It highlighted the observation that residence-based reservations are impermissible in PG medical courses, and that State quota seats—apart from a reasonable number of institution-based reservations—must be filled strictly on the basis of merit in the All-India examination. The Court also cited Jagdish Saran, noting:

“If equality of opportunity for every person in the country is the constitutional guarantee, a candidate who gets more marks than another is entitled to preference for admission. Merit must be the test when choosing the best… This proposition has greater importance at the higher levels of education such as post-graduate courses.”

The Court found the issue in the present petition identical to that in Sawan Bohra & Another v. State of M.P. & Others, where the Madhya Pradesh High Court had allowed the writ petition on a similar issue.

Consequently, the Chhattisgarh High Court held:

“In view of the proposition of law laid down by the Apex Court in Dr. Tanvi Behl (supra), Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, are quashed as being ultra vires and violative of Article 14 of the Constitution of India. The State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11(a) and (b).”

The judgment included a headnote underscoring the primacy of merit:

“While granting admissions, especially to higher and specialised courses, merit must prevail to safeguard educational standards; relaxing merit at such levels under the guise of institutional or domicile reservation risks compromising critical professional excellence.”

Case Details

• Case Title: Dr. Samriddhi Dubey D/o Shri Sandeep Dubey v. State of Chhattisgarh & Others
• Case Number: WPC No. 5937 of 2025
• Court: High Court of Chhattisgarh at Bilaspur
• Coram: Hon’ble Mr. Ramesh Sinha, Chief Justice; Hon’ble Mr. Bibhu Datta Guru, Judge
• Date of Judgment: 20/11/2025
• Citation: 2025:CGHC:56543-DE

For Petitioner(s):
Mr. Rajeev Shrivastava, Senior Advocate, assisted by Mr. Sandeep Dubey, Mr. Manas Vajpai, and Mr. Kaif Ali Rizvi, Advocates.

For Respondent No. 1 to 3 (State of Chhattisgarh & Others):
Mr. Shashank Thakur, Deputy Advocate General.

For Respondent No. 4 (National Medical Commission):
Ms. Shreya Pawan Daga, holding the brief of Mr. Dheeraj Wankhede, Advocate.

For Respondent No. 5 (Director General):
Ms. Anmol Sharma, Standing Counsel.

[Read Order]