MP High Court rules that capping PG-medical seats only for in-state MBBS graduates is unconstitutional

The Madhya Pradesh High Court has delivered a historic ruling, declaring the state rule capping PG medical seats exclusively for in-state MBBS graduates in private colleges as unconstitutional. This decision opens up a significant number of MD/MS/PG Diploma seats to NEET PG 2025 aspirants from across India. The court emphasized the Supreme Court's mandate of a maximum 50% reservation cap. Read on to understand the legal background, the implications for the 2025 counselling process, and how this ruling champions meritocracy in postgraduate medical education.

In a significant judicial intervention that promises to reshape the landscape of postgraduate medical admissions, the Madhya Pradesh High Court has declared a state rule, which mandated a near-exclusive reservation for in-state MBBS graduates in private medical colleges, as unconstitutional. The ruling, delivered in the midst of the NEET PG 2025 counselling process, upholds the principles of meritocracy and non-discrimination, ensuring that highly-ranked candidates who completed their MBBS outside Madhya Pradesh are no longer unfairly excluded from securing seats in the state's private institutions.

​The contentious rule, contained within the state's Medical Education Admission Rules, 2018 (as amended in 2025), effectively reserved 100% of the MD/MS/PG Diploma seats in private colleges through a combination of institutional preference, Non-Resident Indian (NRI) quota, and In-service reservation. The High Court, citing binding precedents from the Supreme Court, firmly established that total reservation, in any form, cannot exceed a 50% cap in private educational institutions. This landmark decision paves the way for a more open and equitable counselling process for thousands of NEET PG aspirants nationwide.

​The Constitutional Conflict: 100% Cap vs. 50% Mandate 

​The core of the litigation revolved around the state government's attempt to grant absolute preference to candidates who completed their undergraduate (MBBS) degree from a college situated within Madhya Pradesh. The High Court meticulously examined how this rule, when combined with other reserved quotas, breached the legal ceiling on reservation.

• ​The Impugned Rule: The petitioners successfully argued that the state's amendment, dated September 3, 2025, which restricted eligibility exclusively to MBBS graduates from medical colleges in MP, amounted to an impermissible 100% institutional reservation in all but name.
• ​Supreme Court Precedents: The High Court relied heavily on landmark Supreme Court judgments, such as Dr. Tanvi Behl vs. State of Madhya Pradesh and Saurabh Chaudri vs. Union of India, which unequivocally held that: 
  • ​Reservation based on domicile or residence in postgraduate medical courses is generally unconstitutional.
  • ​While a reasonable degree of institutional preference is permissible, the overall total reservation (including all categories like SC/ST/OBC, NRI, In-service, and institutional preference) cannot exceed 50%.
  • ​The Court observed that with existing reservations (e.g., 15 % NRI Quota and 30 % In-service Quota, plus the remaining seats going to institutional preference), the effective reservation hit the 100 % mark, which is legally untenable.
• ​Violation of Articles 14 and 15: The bench concluded that the rule violated Article 14 (Equality before law) and Article 15 (Prohibition of discrimination) by creating an unjustifiable classification between MBBS graduates of MP and those from other states, thereby preventing meritorious candidates from competing for the remaining seats.

​Immediate Impact on NEET PG 2025 Counselling 

​The quashing of the institutional preference rule has direct and significant consequences for the ongoing NEET PG 2025 state counselling conducted by the Directorate of Medical Education (DME), MP, for private medical colleges. This ruling mandates an immediate overhaul of the seat allotment matrix.

• ​Opening Up Seats: A significant block of seats, previously locked for internal candidates, will now be treated as open/unreserved seats available to all NEET PG qualified candidates from across India on the basis of pure merit. This could lead to a substantial increase in the available seats for outside state candidates in Madhya Pradesh private medical colleges.
• ​Revised Seat Matrix: The DME will be required to issue a revised seat matrix for the subsequent counselling rounds (Mop-Up and Stray Vacancy) to reflect the court's order. The new matrix must adhere to the maximum 50% reservation cap, treating at least 50 % of the seats in private colleges as 'All India Open Merit' seats.
• ​Fairer Competition: The judgment ensures that candidates who excelled in the NEET PG exam, regardless of where they completed their MBBS, now have a fair chance to secure a specialty seat. This will intensify competition, but purely on the basis of NEET PG All India Rank (AIR), rewarding merit as intended by the national common entrance exam.
• ​Counselling Redirection: The High Court's directive mandates the State to permit the petitioners and all other similarly situated candidates (outside state MBBS graduates) to register and participate in the counselling process. This might require a brief reopening of the registration and choice-filling window to allow excluded candidates to apply.

​Key Takeaways for PG Aspirants Nationwide 

​This ruling is a powerful affirmation of the judiciary's role in safeguarding the principle of merit in higher professional education. It has broader implications for institutional preference policies in other states as well.

• ​Merit Above All: The judgment underscores the principle that for highly specialized postgraduate courses, merit must prevail over local preferences, protecting the standard of medical education. Institutional preference, when applied excessively, often undermines this core objective.
• ​Legal Scrutiny on Quotas: Aspirants should be aware that reservation policies, particularly those implemented by state governments or private bodies, are continuously under judicial scrutiny. Any policy that creates an overly restrictive eligibility barrier or breaches the 50 % reservation ceiling is vulnerable to legal challenge.
• ​The Power of Precedent: The ruling reaffirms the binding nature of Supreme Court judgments like Pradeep Jain, Saurabh Chaudri, and Tanvi Behl. It acts as a strong deterrent against states attempting to monopolize PG seats for their own graduates through back-door reservation mechanisms.
• ​Strategy Shift: Candidates who previously avoided MP's private colleges due to the effective exclusion can now include them in their preference list, especially in the upcoming Mop-Up rounds. This requires a strategic re-evaluation of their choice-filling options based on the expected cut-off relaxation for open category seats.

​Conclusion

​The Madhya Pradesh High Court's ruling to quash the 100 % institutional preference cap for PG medical seats in private colleges is a watershed moment for medical aspirants. By dismantling an unconstitutional barrier, the Court has not only corrected a grave injustice for thousands of students but also reinforced the constitutional and judicial mandate that merit, as reflected by the NEET PG score, must be the paramount factor in specialty medical education. The focus now shifts to the DME, MP, to swiftly implement the judgment and ensure a transparent and fair re-allotment of seats in the remaining rounds of the NEET PG 2025 counselling.

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