The Madhya Pradesh High Court has invalidated a state-imposed territorial restriction on eligibility for NEET-PG admissions, affirming that merit-based national entrance exams cannot be undermined by state-level residency conditions. This ruling reinforces the primacy of uniform national standards in medical education admissions and sets a critical precedent against discriminatory eligibility criteria.
Background & Facts
The Dispute
The petitioners, including Dr. Maulshree Agrawal, challenged Notification dated 03.09.2025 issued under Section 12 of the Madhya Pradesh Niji Vyavsayik Shikshan Sanstha (Pravesh Ka Viniyam Evam Shulk Ka Nirdharan) Adhiniyam, 2007. The notification amended Condition No.5 of Schedule-I of the Madhya Pradesh Chikitsa Shiksha Pravesh Niyam, 2018, restricting eligibility for PG counseling to candidates who completed their MBBS from medical colleges within Madhya Pradesh. This condition applied even to the NRI quota, effectively barring graduates from other states from participating unless no local candidates remained.
Procedural History
- The petition was filed under Article 226 of the Constitution challenging the legality of the amended rule.
- The petitioners had qualified in NEET-PG 2025 and sought admission to postgraduate medical courses.
- The State conducted counseling in rounds, with the first round concluding before the petition was filed.
- The petitioners argued they met all eligibility criteria under Serial Nos. 1 to 4 of Schedule-I but were excluded due to the new territorial condition.
- The State contended that the relaxation clause in the last column of Schedule-I applied only after the first round, and since the second round had ended, no relief was available.
Relief Sought
The petitioners sought immediate inclusion in the counseling process for PG courses, declaration of their eligibility, and quashing of the discriminatory condition in the 2018 Rules.
The Legal Issue
The central question was whether imposing a territorial restriction on MBBS graduates for NEET-PG admissions violates Article 14 of the Constitution by creating an arbitrary classification that has no rational nexus with the objective of selecting meritorious candidates.
Arguments Presented
For the Petitioner
The petitioners relied on P.A. Inamdar v. State of Maharashtra and All India Institute of Medical Sciences v. V. K. Jain to argue that NEET-PG is a national-level entrance examination designed to ensure uniformity and merit-based selection. They contended that the territorial condition introduced by the State was an unauthorized addition to the eligibility criteria, not contemplated under the parent Act or the National Medical Commission Act, 2019. The condition, they argued, discriminated against qualified candidates solely on the basis of their place of graduation, which bears no reasonable connection to clinical competence or public health objectives.
For the Respondent/State
The State argued that the relaxation clause in the last column of Schedule-I was intended to benefit local institutions by prioritizing Madhya Pradesh MBBS graduates. It claimed the condition was a policy measure to retain medical talent within the State and that the relaxation applied only after the first round of counseling. The State further asserted that the petitioners had missed the window for relief as the second round had concluded.
The Court's Analysis
The Court examined the nature of NEET-PG as a centralized, merit-based system under the National Medical Commission Act, 2019, and held that state-level amendments imposing residency conditions directly conflict with the statutory framework governing medical admissions. The Court observed that the principle of equality under Article 14 prohibits arbitrary classifications that lack a reasonable nexus to the object of the law.
"The condition that only MBBS graduates from Madhya Pradesh institutions are first eligible for counseling creates an artificial and discriminatory barrier, which has no rational connection to the goal of selecting the most qualified candidates for postgraduate medical training."
The Court rejected the State’s argument that the relaxation clause applied only after the first round, noting that the clause explicitly stated it would operate "in case the candidates are not available" - a condition that, by the petitioners’ unchallenged evidence, was met in subsequent rounds. The Court emphasized that procedural deadlines cannot override substantive rights when the eligibility criteria themselves are unlawful.
The Court further held that the State’s policy rationale - retaining local talent - could not justify exclusion of otherwise qualified candidates from a national exam. Such a rationale, if accepted, would permit every state to impose similar restrictions, fracturing the national medical education framework.
The Verdict
The petitioners succeeded. The Court held that the territorial eligibility condition in Schedule-I of the 2018 Rules is unconstitutional under Article 14. The petitioner was directed to be registered for counseling, with the caveat that final admission would require court approval. The Court preserved the integrity of the ongoing process while invalidating the discriminatory rule.
What This Means For Similar Cases
Territorial Restrictions in Medical Admissions Are Unconstitutional
- Practitioners must challenge any state rule that imposes residency or institutional location requirements for NEET-PG or similar national entrance exams.
- The judgment establishes that national merit systems cannot be diluted by state-level preferences, even if framed as "relaxation" or "priority."
Relief Is Available Even After Counseling Rounds Begin
- If a rule is found to be unlawful, eligibility cannot be denied on the basis of procedural timelines alone.
- Petitioners may seek interim relief even after counseling has commenced, provided they can demonstrate they meet all other statutory criteria.
State Rules Must Align with Central Statutory Framework
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Any state notification amending eligibility criteria for national exams must be consistent with the parent Act (e.g., NMC Act, 2019).
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Courts will strike down rules that add conditions not authorized by central legislation, reinforcing the doctrine of federal supremacy in education policy.
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Practitioners should immediately review state-level admission notifications for similar territorial or institutional restrictions.
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File writ petitions under Article 226 where eligibility criteria conflict with national standards.
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Cite this judgment to oppose any attempt to prioritize local graduates over national merit in medical admissions.
