Dr. Tanvi Behl v. Shrey Goel & Ors.

Case Citation: [2025] 1 S.C.R. 1209; 2025 INSC 125 (India).

Court: Supreme Court of India

Bench: Hrishikesh Roy J.; Sudhanshu Dhulia J.; S.V.N. Bhatti J.

Judgment Authored by: Sudhanshu Dhulia J.

Date of Judgment: 29 January 2025

Civil Appeal Nos.: 9289-9291 of 2019 & W.P. (C) No. 1183/2020

Parties: Appellant – Dr. Tanvi Behl

Respondents – Shrey Goel & Ors. (including Chandigarh Administration and the Government Medical College and Hospital, Chandigarh)

Brief Introduction

Among the recurring constitutional tensions in Indian medical education, few have proved more persistent than this: can a State or Union Territory carve out postgraduate medical seats exclusively for local residents? On 29 January 2025, a three-judge bench of the Supreme Court of India provided a firm and unambiguous answer. Dr. Tanvi Behl v. Shrey Goel & Ors.[1] is a judgment that consolidates four decades of judicial thinking on domicile, merit, and equal opportunity in higher professional education. It is significant not because it announces a radically new legal position, but because it draws a definitive line that leaves no room for administrative manoeuvring. For aspiring postgraduate medical specialists across India who compete on merit, it represents a constitutional assurance that their national rank will not be subordinated to parochial residential criteria. For State governments, it is a clear instruction that the era of quietly adjusting PG seat quotas in favour of local residents is constitutionally foreclosed.

Facts of the Case

The Government Medical College and Hospital, Chandigarh (the Medical College) is the sole medical institution in the Union Territory. For the 2019 postgraduate admission cycle, it had 64 seats within the State quota. Rather than allocating these seats purely on national merit, the College divided them into two distinct pools. The first was an Institutional Preference Pool, which reserved seats for candidates who had completed their MBBS degree from the Medical College itself. The second, and the category that gave rise to this litigation, was the UT Chandigarh Pool. To qualify for this pool, a candidate was required to satisfy at least one of the following criteria: five years of study anywhere in Chandigarh at any educational stage; parents who had resided continuously in the Union Territory for five years; or the candidate or parents holding immovable property within Chandigarh for a minimum of five years. Documentary proof could be provided through certificates issued by school principals, the Deputy Commissioner, or a Tehsildar.

The practical consequence of this arrangement was severe. Every single seat within the State quota was effectively pre-allocated to either Medical College graduates or individuals connected to Chandigarh by residence or property. Candidates ranked considerably higher on the all-India NEET merit list but lacking any residential connection to the Union Territory were shut out entirely. Petitions were filed before the Punjab and Haryana High Court challenging the UT Chandigarh Pool as constitutionally invalid. The High Court agreed with the petitioners and directed that the impugned residential quota seats be re-filled strictly on the basis of NEET merit. Aggrieved by that decision, the Medical College and certain already-admitted students approached the Supreme Court. Given the broader constitutional question at stake, the matter was referred to a larger bench for an authoritative pronouncement.

III. Legal Issues

The Supreme Court formulated the following questions for determination:

(i) Whether providing domicile or residence-based reservation in postgraduate medical courses within the State quota is constitutionally invalid and impermissible under Article 14[2] of the Constitution of India.

(ii) If such reservation is permissible, to what extent and in what manner may States implement it.

(iii) If such reservation is impermissible, how must State-quota seats, apart from lawfully maintained institutional preference seats, be filled going forward.

Arguments Presented

Appellant (Dr. Tanvi Behl): Dr. Behl contended that the UT Chandigarh Pool created an arbitrary and wholly unreasonable classification among citizens based solely on their place of residence or that of their parents. The submission drew heavily on the long line of precedents beginning with Jagadish Saran v. Union of India[3] and consolidating in Dr. Pradeep Jain v. Union of India[4] and the Constitution Bench ruling in Saurabh Chaudri v. Union of India.[5] At the postgraduate level, it was argued, merit must reign supreme because the country’s specialist healthcare capacity simply cannot be compromised by local residential preferences. The appellant sought a declaration that residence-based reservation for PG seats is void and an order to fill the impugned seats strictly by NEET rank.

Respondents (Medical College/State/Admitted Students): The respondents defended the prospectus on grounds of institutional autonomy and State investment. They contended that States bear substantial infrastructural costs and are thus entitled to reflect local educational interests in their admission policies. It was further argued that neither Article 14 nor Article 15 expressly prohibits residential preference for educational admissions and that a limited connection criterion has a rational relationship with the goal of producing doctors who will practise locally. Equity arguments were also pressed on behalf of students who had already been admitted and were midway through their PG programmes, on the basis of legitimate expectation and the severe disruption that cancellation would cause to their academic careers.

Court’s Reasoning and Analysis

The Court began its analysis by charting the trajectory of three foundational precedents that together settled the constitutional framework. In Jagadish Saran v. Union of India[6]the Court had held that institutional preference at the PG level constitutes a reasonable classification under Article 14 because it is limited in scope and bears a rational nexus to the objective of local service delivery. In Dr. Pradeep Jain v. Union of India[7] a three-judge bench recognised that a modest degree of residence-based preference could be tolerated at the undergraduate MBBS stage where regional backwardness or under-served local health needs provided justification, but simultaneously held that domicile-based criteria at the postgraduate stage are constitutionally impermissible. The Constitution Bench in Saurabh Chaudri v. Union of India[8] settled the matter definitively at the five-judge level, dismissing the claims of Delhi residents who sought PG admissions in Delhi institutions on the strength of their residential status.

In the present case, the Court was not asked to depart from this line of authority; it was asked to apply and reaffirm it in the context of the UT Chandigarh Pool. The bench’s own substantive contribution lay in clarifying the concept of domicile as it exists in Indian constitutional law. Relying on Article 5[9] of the Constitution and on the Full Bench ruling in The State v. Narayandas Mangilal Dayame[10] the Court underscored that India acknowledges only a single, unified concept of domicile in the territory of India. There is no such thing, in Indian constitutional law, as a provincial or State domicile. The Court found that when State authorities loosely use the word ‘domicile’ to mean ‘residence’ or ‘local presence,’ they cause, as earlier held in Dr. Pradeep Jain v. Union of India,[11]radiations that work against the unity and integrity of the country. Such semantic carelessness cannot serve as a constitutional fig leaf for what is essentially territorial discrimination.

The Court also elaborated on why the UG/PG distinction is constitutionally meaningful rather than arbitrary. At the undergraduate MBBS level, States invest in facilities, general practitioners are needed in greater numbers across smaller towns, and a modest local preference can be shown to bear a rational connection to the goal of meeting local healthcare needs. At the postgraduate level, the calculation changes entirely. MD and MS programmes are fewer in number, the specialists they produce are a scarce national resource, and rigorous all-India competition best ensures that the most capable candidates secure these coveted places. A residential filter at this stage does not merely disadvantage an individual candidate; it may deprive the nation of talent in critical areas of specialised medicine. The Court also drew on subsequent decisions including Magan Mehrotra v. Union of India[12] and Neil Aurelio Nunes v. Union of India[13] which had consistently affirmed and applied Dr. Pradeep Jain v. Union of India,[14]in later admission disputes.

Judgment and Ratio Decidendi

The Supreme Court upheld the Punjab and Haryana High Court’s decision and declared that domicile or residence-based reservation in postgraduate medical courses within the State quota is constitutionally impermissible and violative of Article 14.[15] All State-quota PG seats, other than a reasonable number validly reserved for institutional preference, must be filled purely on the basis of all-India NEET rank. Specifically, of the 64 State-quota seats in dispute, 32 filled on institutional preference grounds were upheld as valid, while the remaining 32 UT Chandigarh Pool seats were struck down as unconstitutional. The Court issued the following directions:

(i) Future prospectuses must remove all residence or domicile criteria from PG seat allocation.

(ii) Institutional preference seats remain constitutionally permissible but only to a reasonable proportion and only where demonstrably connected to a legitimate objective.

(iii) Students who had already been admitted under the invalidated residential quota and were pursuing their PG programmes at the time of the judgment were protected on equitable grounds; their ongoing enrolments and degrees were not disturbed.

(iv) All State authorities and Union Territories were directed to align future PG medical admission policies with the all-India NEET merit framework, and to use the terms ‘domicile’ and ‘residence’ accurately and in accordance with their distinct constitutional meanings.

The ratio decidendi may be stated as: domicile or residence, as a classification criterion for State-quota seats in postgraduate medical admissions, lacks a sufficiently close and proximate nexus with any legitimate constitutional objective at the advanced specialised level of medical education; it amounts to an arbitrary restriction on the rights of citizens guaranteed equal treatment under Article 14⁴ and is therefore constitutionally void.

VII. Critical Analysis

The judgment is, on the whole, doctrinally coherent and practically welcome. Its most valuable contribution is its insistence on terminological precision regarding domicile. Indian State governments have, for years, deployed the word ‘domicile’ as a politically convenient shorthand for residential exclusion, well aware that the term carries administrative resonance. By carefully unpacking the constitutional meaning of domicile, tracing its lineage from D.P. Joshi v. State of Madhya Bharat [16] through The State v. Narayandas Mangilal Dayame[17] and onward to Dr. Pradeep Jain v. Union of India,[18] the Court compels administrators to acknowledge precisely what they are doing. That acknowledgment, in turn, makes the practice far more vulnerable to constitutional challenge, and rightly so.

The UG/PG distinction is intellectually well-grounded. General practitioners trained under an MBBS programme serve a wide range of basic healthcare needs at the community level, and some preference for local candidates can plausibly be tied to the goal of plugging primary care gaps in smaller towns. Specialist doctors trained at the postgraduate level, on the other hand, are a scarce and genuinely national resource. Cardiothoracic surgeons, neurologists, and haematologists are not simply local assets; they serve regional and national patient populations. Allowing residential preference to determine who occupies these seats is constitutionally indefensible, and the Court correctly treats it as such.

That said, the judgment is not without gaps. The Court does not engage with the very real policy challenge that many States and Union Territories face in ensuring that PG-trained specialists actually serve in local healthcare systems once qualified. The judgment closes off one avenue, namely residential selection, without pointing towards permissible alternatives such as service bonds, rural posting requirements, or financial incentive schemes that might address genuine local specialist shortfalls through constitutionally sound means. A brief discussion of what States may lawfully do, rather than only what they may not do, would have added practical value without diluting the constitutional ruling.

The protection granted to students already admitted under the residential quota is equitable in spirit but creates a logical tension that the judgment does not fully resolve. The Court accepts that the admissions were unconstitutional, yet insulates their consequences from correction by invoking equity. While there is obvious practical sense in not disrupting doctors midway through specialist training, the Court could have addressed this tension with greater analytical care rather than simply treating it as a matter of discretionary relief.

VIII. Conclusion

Dr. Tanvi Behl v. Shrey Goel & Ors.[19] does precisely what a sound constitutional judgment should do: it applies settled principles to a concrete factual situation with clarity, discipline, and consistency. The ruling leaves no room for States to revive residential preferences through creative reclassification or softer eligibility criteria. Its three lasting contributions are the reaffirmation that Indian domicile is a single, indivisible national concept; the confirmation that institutional preference, though permissible within reasonable bounds, cannot be stretched into a proxy for local exclusion; and the unequivocal direction that national merit, as tested through NEET, must govern the selection of India’s postgraduate medical specialists. For thousands of candidates who invest years preparing for these admissions on the faith that rank will determine outcome, the judgment is a meaningful constitutional reassurance. For States tempted to continue experimenting with eligibility criteria that produce locally skewed PG seats, it is an equally unambiguous warning.

Reference(S):

Cases

1. P. Joshi v. State of Madhya Bharat, AIR 1955 SC 334, [1955] 1 S.C.R. 1215 (India).
2. State v. Narayandas Mangilal Dayame, AIR 1958 Bom. 68 (F.B.), (1957) 59 Bom. L.R. 901, 1958 Cri. L.J. 161 (India).
3. Jagadish Saran v. Union of India, (1980) 2 S.C.C. 768, AIR 1980 SC 820, [1980] 2 S.C.R. 831 (India).
4. Pradeep Jain v. Union of India, 1984 INSC 117, (1984) 3 S.C.C. 654, AIR 1984 SC 1420, [1984] 3 S.C.R. 942 (India).
5. Magan Mehrotra v. Union of India, (2003) 11 S.C.C. 186 (India).
6. Saurabh Chaudri v. Union of India, (2003) 11 S.C.C. 146, AIR 2004 SC 361 (India).
7. Neil Aurelio Nunes v. Union of India, 2022 INSC 526, (2022) 4 S.C.C. 1 (India).
8. Tanvi Behl v. Shrey Goel, 2025 INSC 125, [2025] 1 S.C.R. 1209 (India).

Constitutional Provisions

9. INDIA CONST. art. 5.
10. INDIA CONST. art. 14.

[1] Dr. Tanvi Behl v. Shrey Goel, 2025 INSC 125, [2025] 1 S.C.R. 1209 (India).

[2] INDIA CONST. art. 14.

[3] Jagadish Saran v. Union of India, (1980) 2 S.C.C. 768, AIR 1980 SC 820, [1980] 2 S.C.R. 831 (India).

[4] Dr. Pradeep Jain v. Union of India, 1984 INSC 117, (1984) 3 S.C.C. 654, AIR 1984 SC 1420, [1984] 3 S.C.R. 942 (India).

[5] Saurabh Chaudri v. Union of India, (2003) 11 SCC 146 (India).

[6] Jagadish Saran, (1980) 2 S.C.C. at 775.

[7] Pradeep Jain, (1984) 3 S.C.C. at 662.

[8] Saurabh Chaudri, (2003) 11 S.C.C. 146.

[9] INDIA CONST. art. 5.

[10] State v. Narayandas Mangilal Dayame, AIR 1958 Bom. 68 (F.B.), (1957) 59 Bom. L.R. 901, 1958 Cri. L.J. 161 (India).

[11] Pradeep Jain, (1984) 3 S.C.C. at 662.

[12] Magan Mehrotra v. Union of India, (2003) 11 S.C.C. 186 (India).

[13] Neil Aurelio Nunes v. Union of India, 2022 INSC 526, (2022) 4 S.C.C. 1 (India).

[14] Pradeep Jain, (1984) 3 S.C.C. at 662.

[15] INDIA CONST. art. 14.

[16] D.P. Joshi v. State of Madhya Bharat, AIR 1955 SC 334, [1955] 1 S.C.R. 1215 (India).

[17] Narayandas Mangilal Dayame, AIR 1958 Bom. at 72.

[18] Pradeep Jain, (1984) 3 S.C.C. at 662.

[19] Tanvi Behl, [2025] 1 S.C.R. at 1231.