Chhattisgarh High Court strikes down state’s 2025 PG-medical admission rules as discriminatory and unconstitutional

The Chhattisgarh High Court has delivered a landmark ruling, declaring Rule 11(a) and 11(b) of the Chhattisgarh PG Medical Admission Rules, 2025, unconstitutional. The court relied on the Supreme Court's precedent set in the Dr. Tanvi Behl case, which affirmed that merit must prevail over domicile or blanket institutional preference in postgraduate medical admissions. This decision mandates that state quota seats, barring a reasonable institutional preference, must be filled strictly based on the NEET PG All-India Merit Rank. This verdict is a massive victory for aspirants who secured their MBBS degrees outside Chhattisgarh and ensures a level playing field, reinforcing the fundamental right to equality under Article 14 of the Constitution.

The landscape of postgraduate (PG) medical admissions in Chhattisgarh has been fundamentally reshaped by a significant verdict from the Chhattisgarh High Court. Acting on a writ petition filed by aspirants like Dr. Samriddhi Dubey, a Division Bench of the court quashed Rule 11(a) and Rule 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025. These rules, which effectively created a two-tiered system for PG admissions, were deemed unconstitutional and violative of Article 14—the constitutional guarantee of Right to Equality.

​The core of the ruling rests on the binding legal principle established by the Supreme Court in the landmark case of Dr. Tanvi Behl v. Shrey Goel & Others (2025). This precedent clearly held that residence-based reservation or any provision that unduly favors candidates solely based on where they completed their undergraduate (MBBS) degree is impermissible in specialized higher medical courses. This verdict is a resounding affirmation that merit, as demonstrated through the NEET PG examination, must be the predominant factor in selecting the nation’s future medical specialists. The judgment is a major boost for the transparency and fairness of the counselling process for the State Quota seats.

​ The Impugned Rules and Their Unconstitutional Effect

​The challenge in the Chhattisgarh High Court centered on specific provisions within the 2025 Rules that created an unjustifiable classification among domicile candidates. The court found that these rules created a system that amounted to a near 100% reservation for a select group, thereby discriminating against equally meritorious students.

• ​Rule 11(a) and 11(b) Quashed: These rules concerned the preferential allocation of the State Quota seats. 
  • ​Rule 11(a): Gave first preference to candidates who obtained their MBBS degree from medical colleges within the State of Chhattisgarh.
  • ​Rule 11(b): Stipulated that only if seats remained vacant after exhausting the Rule 11(a) category would they be offered to candidates who were natives/domicile residents of Chhattisgarh but obtained their MBBS degrees from outside the state.
• ​Violation of Article 14: The court found that this two-tiered preferential system discriminated between candidates who were all permanent residents of Chhattisgarh. It created an unequal classification based purely on the location of the candidates' MBBS institution. This residence-based discrimination was held to be arbitrary and lacking a reasonable nexus with the object of promoting specialized medical education, which should prioritize merit.
• ​Impact: By quashing these rules, the High Court has directed the State to eliminate this discriminatory practice, ensuring that all eligible candidates compete for the state quota seats primarily on the basis of their NEET PG merit and not the geography of their prior education.

 The Dr. Tanvi Behl Precedent: Merit Over Domicile

​The Chhattisgarh High Court's decision was explicitly grounded in the principles laid down by the Supreme Court in the Dr. Tanvi Behl case, which has become the definitive legal authority on PG medical admission criteria. The Supreme Court's rationale clarifies the distinction between UG and PG medical admissions.

• ​UG vs. PG Admissions: The Supreme Court has consistently held that some degree of residence-based reservation or preference is permissible for MBBS (UG) courses to address local needs and the State’s investment in infrastructure.
• ​Specialized PG Courses: However, for Postgraduate Medical Courses (MD/MS/PG Diploma), the imperative shifts decisively to merit and professional excellence. The Supreme Court clarified that relaxing merit for specialized learning, whether under the guise of domicile or excessive institutional preference, risks compromising the standards of healthcare.
• ​Permissible Preference: The Supreme Court allowed for only a reasonable quantum of institutional preference—a limited number of seats reserved for those who completed their MBBS from the same university/institution. Beyond this reasonable quantum, all State Quota seats must be filled strictly based on the candidate's All-India Merit in the NEET PG examination.
• ​Direct Impact on State Quota: The judgment reaffirms that the 50% State Quota seats must primarily adhere to merit, preventing states from creating reservations that effectively nullify the NEET PG ranking for large segments of the state’s domicile candidates.

Implications for NEET PG 2025 Aspirants in Chhattisgarh

​This ruling has immediate and far-reaching consequences for all candidates participating in the Chhattisgarh NEET PG 2025 counselling process.

• ​Level Playing Field: The quashing of Rules 11(a) and 11(b) creates a single, unified merit list for all permanent residents of Chhattisgarh who have qualified for NEET PG, regardless of where they obtained their MBBS degree (whether in Chhattisgarh, outside the state, or even abroad, provided they meet all other eligibility criteria).
• ​Increased Competition for In-State Graduates: Candidates who graduated from MBBS colleges within Chhattisgarh must now compete directly on their NEET PG score with all other eligible domicile candidates, potentially reducing their historical advantage.
• ​Boost for Out-of-State Graduates: Conversely, candidates who are Chhattisgarh natives but studied MBBS outside the state now have an equal and fair opportunity to secure a PG seat in their home state based purely on their merit.
• ​Counselling Process Revision: The Directorate of Medical Education (DME), Chhattisgarh, will be required to issue a revised merit list and possibly a revised counselling notification to implement this court order immediately, before or during the ongoing Round 1 process.

​Conclusion

​The Chhattisgarh High Court’s decision, anchored in the Supreme Court’s definitive Dr. Tanvi Behl ruling, is a landmark verdict for the integrity of postgraduate medical admissions. By striking down the discriminatory preferences embedded in the 2025 Rules, the court has prioritized merit and equality in the selection of future specialists. This move ensures that the most deserving candidates secure the limited PG medical seats, irrespective of their institution of undergraduate study. Aspirants for the NEET PG 2025 counselling in Chhattisgarh must closely monitor the DME's upcoming revised schedule and merit list, as the admission landscape has now fundamentally shifted in favor of All-India Merit.

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