Madhya Pradesh High Court Strikes Down 100 percent Reservation in PG Medical Courses

Court Declares Institutional Preference for Madhya Pradesh MBBS Graduates Unconstitutional

In a landmark judgment, the Madhya Pradesh High Court has quashed the amendment notification dated September 3, 2025, which provided for 100% institutional preference in postgraduate (PG) medical courses to MBBS graduates from Madhya Pradesh. The court held this provision unconstitutional, declaring it a violation of Article 14 of the Constitution of India.

The division bench, comprising Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf, delivered the verdict in the case of Sawan Bohra v. State of M.P. The petitioners, MBBS graduates aspiring for PG medical seats, challenged the notification that amended the 2018 admission rules, arguing it contravened Supreme Court rulings that reservations should not exceed 50% of the total seats.

The State of Madhya Pradesh defended the notification, claiming it aimed to retain local talent and enhance the state's healthcare system. However, the court found that the rule effectively excluded non-Madhya Pradesh graduates from participating in the counseling process, as they could not register for the first round, thereby disallowing them from subsequent rounds.

Citing precedents from the Supreme Court, including Pradeep Jain v. Union of India and Saurabh Chaudri v. Union of India, the High Court reiterated that reservations in any form, including institutional preference, should not surpass 50% of the available seats. The court underscored that the constitutional mandate for merit-based admissions must be preserved, especially for PG courses where excellence is paramount.

Furthermore, the court noted that the reserved seats, including a 15% quota for NRIs and a 30% quota for in-service candidates, along with institutional preference, resulted in a total reservation exceeding the permissible limit. The judgment emphasized that such a comprehensive reservation scheme violates the principles of equality and merit.

The court directed the state to ensure compliance with the 50% reservation cap and allow all eligible candidates, irrespective of their MBBS graduation state, to register and participate in the counseling process. This decision is restricted to private medical colleges and does not apply to government colleges, where 50% of seats are allocated to the All India Quota.

The ruling has significant implications for the admission process in private medical colleges across Madhya Pradesh, ensuring a fairer distribution of seats and upholding the meritocracy principle in higher education.

Bottom Line:

Institutional preference and reservation in postgraduate medical courses must not exceed 50% of the total seats, adhering to the constitutional mandate and Supreme Court rulings.

Statutory provision(s): Article 14 of the Constitution of India, Madhya Pradesh Medical Education Admission Rules, 2018

Sawan Bohra v. State of M.P., (Madhya Pradesh)(Jabalpur)(DB) : Law Finder Doc Id # 2811176