The Supreme Court’s judgment in Dr. Tanvi Behl vs Shrey Goyal (2025) strikes down domicile-based reservations in post-graduate medical admissions, jeopardizing state health planning. Domicile quotas ensure local specialist pipelines and sustainable investments. Removing them forces states into unpredictable recruitment, undermines federalism, risks worsening healthcare disparities. A balanced approach is essential.
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The recent Supreme Court judgment in Dr. Tanvi Behl v/s Shrey Goyal (2025) has sparked debate about the future of medical education and healthcare federalism in India.
The Supreme Court ruled that domicile-based reservations in post-graduate medical admissions violate Article 14 of the Constitution, which guarantees equality before the law.
The decision overturns a long-standing practice that states have used to ensure a stable supply of medical professionals who are likely to remain and serve within the state's healthcare system.
Domicile-based reservations play a crucial role in aligning state investments in medical education with long-term health system needs.
States invest public resources in medical education with the expectation that graduates will contribute to the local healthcare infrastructure.
The medical seats quotas create a predictable pipeline of doctors who are more likely to remain and serve within the state; this addresses the acute shortage of specialists in many regions.
The Court's dependence on Pradeep Jain v/s Union of India (1984) fails to recognize the fundamental difference between undergraduate and post-graduate medical education.
Undergraduate programs provide foundational training, post-graduate courses develop specialized skills crucial to public health. Removing domicile quotas disrupts this specialist training pipeline, which forces states to depend on unpredictable external recruitment.
The judgment may discourage states from investing in medical education.
Competitive federalism encourages states to develop strong institutions, but if they cannot ensure their investment translates into a local specialist workforce, they may deprioritize funding for government medical colleges.
This could lead to deteriorating infrastructure and widening regional healthcare disparities.
Narrow Interpretation of Constitutional Concerns
The Court's interpretation treats medical colleges merely as professional training institutions, ignoring their broader function as pillars of public health infrastructure.
The right to life under Article 21 encompasses access to adequate healthcare, and government medical colleges are integral to state healthcare systems.
A more balanced approach would integrate domicile quotas with public service obligations. For example, Tamil Nadu's medical education policy links quotas to mandatory service in public institutions.
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Domicile-Based Reservations in Postgraduate Medical
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