This article is part of the UPSC Daily Editorial Analysis, covering The Hindu editorial – " Over-centralisation threatens federal health policy ," published on 6th March, by the best UPSC coaching in Kolkata.
Syllabus: UPSC Mains GS-II (Polity, Governance, Federalism, Social Justice & Health)
The Supreme Court's ruling in the recent Dr. Tanvi Behl vs Shrey Goyal (2025) struck down domicile-based reservations in PG medical admissions, citing a violation of Article 14 (Right to Equality) and emphasizing merit-based selection. However, this decision may weaken State healthcare systems by discouraging investment in medical education and creating shortages of specialists in public hospitals. States rely on domicile quotas to retain trained doctors for local service, ensuring healthcare access in rural areas. While the Court referenced Pradeep Jain (1984), postgraduate education differs as it directly impacts specialized healthcare. The ruling also raises concerns over over-centralization, as States lose autonomy in workforce planning. Instead of eliminating domicile quotas, alternative solutions like mandatory service bonds and hybrid models could balance merit with public health needs. The decision calls for a policy reassessment to align meritocracy with equitable healthcare access.
What is in news?
The Supreme Court's recent judgment in Dr. Tanvi Behl vs Shrey Goyal (2025) has struck down domicile-based reservations in postgraduate medical admissions.
What is the Domicile Quota in Postgraduate Medical Admissions?
The domicile quota is a reservation system in which states reserve a portion of postgraduate medical seats for candidates who are residents of that state.
In PG medical admissions, the Centre conducts counseling for 50% of the total seats. State counseling bodies manage the remaining 50%. Within this state-managed quota, a certain percentage is reserved for domicile candidates to ensure that local students have better access to medical education and contribute to the state’s healthcare system.
Recent Supreme Court Ruling on Domicile Quotas
The court ruled that such reservations violate Article 14 (Right to Equality) of the Constitution and emphasized merit-based admissions.
Impact of Supreme Court Ruling on Domicile Quotas
This ruling overlooks the critical role of domicile quotas in State healthcare planning. By removing these reservations, the judgment may discourage States from investing in medical education and weaken the public healthcare system.
The Need for Domicile Quotas in Postgraduate Medical Education
Ensuring a Stable Healthcare Workforce
- States invest heavily in medical education, hoping that doctors trained locally will serve in State hospitals and rural health centers.
- Without domicile quotas, doctors may move elsewhere after completing their education, creating shortages of specialists in public hospitals.
Difference Between MBBS and Postgraduate Education
- The Supreme Court relied on the Pradeep Jain vs Union of India (1984) judgment, which focused on MBBS admissions.
- However, postgraduate medical training is different—it creates specialists who directly serve in hospitals and contribute to public healthcare.
- If States cannot retain their PG doctors, they may struggle to provide specialized healthcare services.
Challenges for States in Medical Education and Admission Policies
Disincentive for States to Invest in Medical Education
- If States cannot ensure that locally trained doctors stay and serve, they may reduce funding for medical colleges.
- This can lead to declining quality of education, fewer medical seats and weaker healthcare infrastructure.
Central Institutions Have an Advantage which states don’t have
- Institutions like AIIMS, JIPMER and PGIMER have autonomy over admissions, allowing them to maintain high standards and long-term plans.
- State-run medical colleges, however, now lack this autonomy, making it harder for them to plan for future healthcare needs.
Balancing the Right to Health and State Autonomy in Medical Education
Right to Health Under Article 21
- Article 21 guarantees the Right to Life, which includes access to quality healthcare.
- Since public health is a State responsibility, medical colleges must be seen as part of a State’s healthcare system, not just as educational institutions.
- Without domicile quotas, States may struggle to ensure doctors serve in rural and underserved areas.
Over-Centralization Weakens Healthcare Planning
- A one-size-fits-all approach does not work in a country as diverse as India.
- States need the flexibility to plan their medical workforce based on local health challenges.
- Judicial decisions should consider the practical realities of medical education and public health.
Reevaluating Merit in Medical Admissions: Flaws and Judicial Precedents
Flaws in the Current Admission System
- The ruling assumes that merit should be the only criterion for medical admissions.
- However, recent issues with NEET-PG raise questions about how merit is assessed:
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- In 2023, the NEET-PG cutoff was reduced to zero percentile, meaning even those who scored negative marks qualified.
- If the system allows underqualified candidates, it weakens the argument that NEET ensures true meritocracy.
Past Supreme Court Judgments on Merit
- The Supreme Court has previously ruled that merit should serve social needs, not just individual success:
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- Jagdish Saran (1982) – Recognized that merit must be balanced with social justice.
- Pradeep Jain (1984) – Allowed some scope for domicile quotas in State medical institutions.
- Neil Aurelio Nunes (2022) – Affirmed the role of affirmative action in ensuring a diverse workforce.
- These cases highlight that merit must align with public interest, especially in healthcare.
Reevaluating Domicile Quotas: Lessons from the Past and Alternative Approaches
Revisiting the 1984 Precedents
- The healthcare landscape has changed significantly since the 1984 Pradeep Jain ruling.
- The COVID-19 pandemic exposed how States struggle with doctor shortages, especially in rural areas.
- The Supreme Court needs to reassess domicile quotas in the context of today’s healthcare challenges.
Alternative Solutions
Instead of removing domicile quotas entirely, a better approach could be:
- Mandatory service bonds – Doctors could be required to serve in State public hospitals for a few years after completing their PG.
- Hybrid models – Some seats could be reserved for State residents, while others remain open to all India candidates.
Conclusion: Need for a Policy Reassessment with regard to Domicile Quotas
- The Supreme Court’s decision, while promoting meritocracy, does not fully consider State healthcare needs.
- A centralized approach may weaken State medical education and public healthcare services.
- A better model would balance merit, equity and public health priorities, ensuring that medical education serves the larger goal of accessible healthcare for all.
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PRACTICE QUESTION
Q.The removal of domicile quotas in medical admissions ensures meritocracy but challenges State healthcare. Critically analyze. (250 words)
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1. What is the domicile quota in PG medical admissions?
It is a reservation system where States reserve PG medical seats for local students to strengthen their healthcare workforce.
2. What did the recent ruling say about domicile quotas?
The court struck down domicile quotas, citing violation of Article 14 (Right to Equality) and emphasizing merit-based admissions.
3. How does this ruling impact State healthcare?
States may struggle to retain specialist doctors, leading to shortages in public hospitals and rural healthcare.
4. Why do States need domicile quotas?
They invest in medical education, expecting trained doctors to serve locally. Without quotas, doctors may relocate, weakening State healthcare.
5. How is PG medical education different from MBBS admissions?
PG training creates specialists who directly serve in hospitals, making retention crucial for public health services.
6. What are possible alternatives to domicile quotas?
Mandatory service bonds or hybrid models reserving some seats for locals while keeping others open nationally.
