Supreme Court: Reserved Candidates Eligible for Unreserved MBBS Seats

Introduction

This landmark ruling in the case of Ramnaresh @ Rinku Kushwah and others vs. State of Madhya Pradesh and others. supports merit, equity, and equity-based reservations, which the Supreme Court of India had recently rendered to quash a Madhya Pradesh High Court decision that refused to admit deserving reserved category students to MBBS seats of unreserved category. The judgment, which underlines the qualifying reserved category candidates ‘right of representation on UR seats of their merit ‘was delivered by the bench of Justice B. R. Gavai and Justice K. V. Anish Kumar. The Court endorsed the decision in Saurav Yadav and Others v. State of Uttar Pradesh and Others to enforce that candidates belonging to reserved categories must be admitted for UR quota if they have merit. 

Background 

The case essentially focuses on the distribution of MBBS seats in Madhya Pradesh, considering that 5% of the total MBBS seats are reserved for Government School (GS) students under the Madhya Pradesh Education Admission Rules 2018. These seats were moved to the open category because of some vacancies in the GS-UR category of the job. Nevertheless, the appellants further submitted that several meritorious reserved category students studying in government schools could not be considered for these UR-GS seats.
 

The Case 

The appellants who were the reserved category students with higher merit scores claimed that the Madhya Pradesh Department of Medical Education was unjustified in withholding their chances in the UR-GS category. However, candidates of lower merit from the unreserved category were offered the chance and, as a result, the appellants lost their rightful place based on merit. The Madhya Pradesh High Court rejected their petitions following which they sought Supreme Court intervention. 

Facts

MBBS Seat Allocation

The case relates to the distribution of MBBS seats in the Government of Madhya Pradesh, particularly the ‘5% quota’ for Government School (GS) students. 

Vacant Seat Transfer

This 10% of the seats were filled in the GS-UR category for the current academic year as per Rule 2(g) of the Madhya Pradesh Education Admission Rules, 2018 due to the non-opening of these seats last year for admission. 

Meritorious Reserved Candidates

The appellants, who were from reserved category (SC/ST/OBC) students and had studied in government schools, contested that they were more meritorious than UR-GS candidates who got through. 

High Court's Dismissal

The High Court of Madhya Pradesh dismissed the appellants’ petitions hence the appeal to the Supreme Court. 

Issues 

The matter in controversy in the case was whether meritorious reserved category candidates could be turned away from UR-GS seats exclusively due to their category reserved status. The appellants stated that such a denial was against the SC judgment and rule formulated in Saurav Yadav and Anr vs. State of UP case etc., holding that if a candidate belonging to the reserved category secures a sufficiently high percentage to get a UR seat he or she should be admitted. 

Judgment 

The Supreme Court also agreed with the majority of the appellants and it quashed the order of the Madhya Pradesh High Court. The Court held that the failure to permit reserved category candidates with merit to take admission in UR-GS seats is against the principles upheld in the Saurav Yadav case. The bench pointed out that the appellants despite being qualitatively better off than the admitted UR-GS candidates, have been locked out of admission only because of improper implementation of the principles of horizontal and vertical reservation. 

Rationale Behind the Judgment 

The Supreme Court gave this decision based on the Justice of meritocracy. The Court further reiterated its position that, the candidates belonging to the reserved categories if they secure the required percentage of marks, should be treated at par with general candidates and be admitted to the UR seats, if they have a higher percentage of marks. This makes sure that merit is not traded off and that there is no unequal exclusion of equipped folks based on their category. The Court also stated that those attempts to sub-classify candidates within horizontal and vertical reservations ‘as proposed by the respondents’ are legally unsustainable and ultra vires established legal principles. 

Critical Analysis

The recent judgment passed by the Supreme Court is a step forward towards achieving enhancement of the principle of merit in the system of education in India particularly in the field of medical education. Thus, by protecting the interest of meritorious reserved category students and denying them the loss of seats in the unreserved category, the Court has upheld the constitutional provision of equality and non-discrimination. This judgment also stresses the fact that educational institutions and governmental bodies must use the policy of reservation very cautiously so as not to harm the idea of merit and not to produce inequitable results. 

But the judgment also exposes the controversies and issues that may surround the policy of reservation, especially in examinations or admissions. Though the Court has taken a praiseworthy decision, it also needs a critical approach to policy formulation and implementation which has to duty to keep merit and justice in the right proportion. 

Conclusion 

This case is one of the few landmark judgments that has at its core, defended merit to be the benchmark in the proportion of seats in any learning institutions. In a way, the Court has gotten rid of the barrier posed by the Madhya Pradesh High Court’s order so that deserving reserved category students can be rightfully absorbed into the unreserved category where they belong, all in the spirit of equality and justice. 

FAQs 

How does this verdict of the Supreme Court benefit the students belonging to the reserved categories? 

This implies that if an SC/ ST/ OBC candidate secures sufficient marks to qualify for the quota as a single candidate the candidate is also given general category seats. He/she cannot be locked out of these seats merely on the basis that he/she is covered under a reserved category. 

How does this decision affect the potential seats in a government medical college? 

This decision enhances the possibility of meritorious students of the reserved categories to get a seat in government medical colleges if the marks secured by them make them eligible for unreserved category seats. It helps to prevent the discrimination of certain categories of students from others by basing all their evaluations on their performance. 

If I am from the SC/ST/OBC category and secure good percentiles, can I get into general merit seats? 

Yes, it is possible if you have enough marks you can also compete for the general category seats if you are in the reserved category. The matter of the matter is that the SC has stipulated that merit is the main criterion that should be used to fill these seats.

Will this ruling cut down the general category of students’ number of seats? 

The ruling means that only deserving candidates are awarded seats. Even if it means that some of the general category seats are taken by students scoring high percentages in reserved categories, the decision seems to be to reduce social bias and meritocracy in the admission. 

In light of this ruling, how does it position itself to the total reservation system in India? 

Most importantly, this ruling entitles students who belong to any reserved categories but are meritorious enough, to be allowed in general category seats if they pass the cut-off. It underlines the fact that for reservation, one should not compromise on the deserving seat for general category students based on scores.