Context

• The recent Supreme Court judgment in Dr. Tanvi Behl vs Shrey Goyal (2025), which struck down domicile-based reservations in post-graduate medical admissions, marks a pivotal moment in India's medical education policy.
• By dismantling a key mechanism for States to ensure a stable and locally rooted medical workforce, the decision risks exacerbating regional disparities in healthcare access.
• A deeper examination of the judgment reveals potential flaws in its reasoning, particularly in its rigid interpretation of meritocracy and its failure to recognise the intricate relationship between medical education and State health policy.

The Significance of Domicile Quotas in State Health Planning

• Domicile-based reservations in post-graduate medical courses play a crucial role in aligning State investments in medical education with long-term health system needs.
• States invest substantial public resources in medical education with the expectation that graduates will contribute to the local healthcare infrastructure.
• This is particularly significant given the acute shortage of specialists in many regions.
• By ensuring that a portion of post-graduate seats are reserved for local candidates, States create a predictable pipeline of doctors who are more likely to remain and serve within the State.

Drawbacks of the SC Judgement

• The Judgement Overlooks an Essential Distinction
  • The SC’s reliance on Pradeep Jain vs Union of India (1984) to justify the elimination of domicile quotas overlooks an essential distinction between undergraduate and post-graduate medical education.
  • While undergraduate medical programs provide foundational training, post-graduate courses are where doctors acquire specialised skills crucial to public health.
  • Removing domicile quotas disrupts this specialist training pipeline, forcing States to rely on unpredictable external recruitment, which is neither efficient nor sustainable.
• Undermining Competitive Federalism and State-Level Health Planning
  • Moreover, the judgment undermines the incentive for States to invest in medical education.
  • Competitive federalism encourages States to develop strong institutions, but if they cannot ensure that their investment translates into a local specialist workforce, they may deprioritise funding for government medical colleges.
  • This could lead to deteriorating infrastructure and an increasing gap between regional healthcare facilities.
  • While premier central institutions like AIIMS and PGIMER retain full autonomy in admissions, State medical colleges, arguably more vital to India's public health system, are denied the same prerogative.
  • This structural imbalance may further weaken State-level healthcare planning.
• Narrow Interpretation of Constitutional Concerns
  • The right to life under Article 21 of the Indian Constitution encompasses access to adequate healthcare.
  • Since public health falls under State legislative competence, the role of government medical colleges extends beyond academics; they are an integral part of the State's healthcare system.
  • The Court’s narrow interpretation, which treats medical colleges merely as institutions for professional training, ignores their broader function as pillars of public health infrastructure.
  • A more holistic approach, recognising the interdependence of medical education, healthcare access, and federalism, is essential for crafting policies that strengthen rather than weaken State healthcare systems.

The Fallacy of Supreme Court’s Reliance on Absolute Meritocracy

• The SC’s insistence on a rigid, meritocratic framework for medical admissions disregards structural inequities within India's medical entrance system.
• The National Eligibility cum Entrance Test (Postgraduate) (NEET-PG) has been criticised for its flaws, including the fact that candidates with negative marks may still qualify due to percentile-based cutoffs.
• Additionally, in 2023, the National Medical Commission lowered the qualifying percentile for NEET-PG to zero to fill vacant seats, raising questions about how merit is assessed in practice.
• If undergraduate admissions consider regional and socio-economic disparities, there is little justification for excluding these factors from post-graduate admissions.
• Prior SC rulings, such as Jagdish Saran vs Union of India (1982) and Neil Aurelio Nunes vs Union of India (2022), have acknowledged that merit cannot be evaluated in isolation from its social context.
• A more meaningful conception of merit should incorporate considerations of regional healthcare needs and the likelihood of candidates serving in underserved areas.
• The Economic Survey 2024-25 has highlighted how domicile-based reservations enhance healthcare access and mitigate regional disparities, reinforcing the argument that an inclusive definition of merit is necessary.

Implications of Over-Centralisation and The Way Forward

• Implications of Over-Centralisation
  • Over-centralisation, especially when driven by judicial rulings, restricts States' ability to formulate policies that align with their socio-economic and public health contexts.
  • If the judiciary and legislatures do not acknowledge the vital role that domicile-based reservations play in sustaining the healthcare workforce, States will struggle to retain medical professionals, ultimately harming public health outcomes.
• The Way Forward: Need for Reconsideration
  • While the Court's decision aligns with legal precedents, it does not adequately reflect the evolving realities of India’s healthcare system.
  • The framework established in Pradeep Jain (1984) was formulated in a different public health landscape, and the challenges of retaining specialists within State health systems have become more pressing, particularly after the COVID-19 pandemic.
  • A more balanced approach would integrate domicile quotas with public service obligations.
  • For instance, Tamil Nadu's medical education policy links quotas to service mandates in public institutions, ensuring that State investment yields tangible healthcare benefits.
  • Rather than eliminating domicile-based reservations outright, judicial and policy frameworks should explore models that balance merit with the need for a stable and regionally distributed medical workforce.

Conclusion

• The SC’s judgment in Dr. Tanvi Behl vs Shrey Goyal (2025) reflects a well-intentioned but overly rigid application of meritocracy.
• By reinforcing centralised control over medical admissions, the ruling undermines State investment in medical education, weakens the public health system, and exacerbates regional disparities.
• If India aims to build a sustainable healthcare framework, judicial doctrine must evolve to accommodate the complex interplay between medical education, federalism, and public health policy.