The Madhya Pradesh High Court has invalidated a state-level restriction that limited NEET-PG admission eligibility to candidates who completed their MBBS within the state, reinforcing the principle that merit-based national entrance exams cannot be undermined by parochial eligibility criteria. This ruling affirms the supremacy of uniform national standards in postgraduate medical education and protects the rights of out-of-state graduates under Articles 14 and 21 of the Constitution.
Background & Facts
The Dispute
The petitioner, Dr. Ankit Goswami, a medical graduate who completed his MBBS outside Madhya Pradesh, sought admission to postgraduate medical courses through the NEET-PG 2025 examination. A notification dated 03.09.2025 amended Schedule-I of the Madhya Pradesh Chikitsa Shiksha Pravesh Niyam, 2018, introducing Condition No.5 that prioritized candidates with MBBS degrees from medical colleges located within Madhya Pradesh for counseling and admission, including under the NRI quota.
Procedural History
- The petitioner qualified NEET-PG 2025 and met all eligibility criteria under Serial Nos. 1 to 4 of Schedule-I.
- The State’s amended rule effectively barred him from participation unless candidates from in-state medical colleges were unavailable.
- The second round of counseling concluded before the petitioner could be considered, despite the rule’s stated relaxation clause.
- The petitioner filed a writ petition under Article 226 challenging the legality of the amendment.
Relief Sought
The petitioner sought immediate inclusion in the counseling process for PG courses, arguing that the relaxation clause in the last column of Schedule-I applied after the first round, and that his eligibility was otherwise complete. He requested permission to register and participate in counseling scheduled from 02.02.2026 to 04.02.2026.
The Legal Issue
The central question was whether Condition No.5 of the Madhya Pradesh Chikitsa Shiksha Pravesh Niyam, 2018, which restricts NEET-PG admission eligibility to MBBS graduates from in-state colleges, violates Article 14 and Article 21 by imposing an arbitrary and discriminatory condition not present in the national NEET-PG framework.
Arguments Presented
For the Petitioner
The petitioner’s counsel argued that the amendment introduced a retrospective and discriminatory condition not found in the original 2018 Rules or the national NEET-PG guidelines. He relied on P. A. Inamdar v. State of Maharashtra to assert that state governments cannot impose additional eligibility criteria that undermine the uniformity of national entrance examinations. He emphasized that the relaxation clause in the last column of Schedule-I was intended to apply after the first round of counseling, and since in-state candidates were unavailable in subsequent rounds, his name should have been included.
For the Respondent/State
The State contended that the relaxation clause was only operative immediately after the first round of counseling and had lapsed once the second round concluded. It argued that the State had the authority under Section 12 of the 2007 Adhiniyam to regulate admission procedures and that the condition promoted local retention of medical talent. It cited State of Karnataka v. Vishwabharathi House Building Cooperative Society to support the State’s regulatory discretion in educational matters.
The Court's Analysis
The Court examined the nature of NEET-PG as a national-level entrance examination governed by the National Medical Commission Act, 2019, and held that state-level amendments imposing residency-based eligibility criteria directly conflict with the statutory objective of uniformity and merit-based selection. The Court observed that the relaxation clause in the last column of Schedule-I was not a conditional exception but a mandatory fallback mechanism triggered upon non-availability of in-state candidates.
"The relaxation is not a discretionary privilege but a procedural safeguard to ensure that seats remain filled when local candidates are absent. To deny its application after the second round defeats the very purpose of the rule."
The Court rejected the State’s argument that the relaxation had lapsed, noting that the rule did not specify a temporal cutoff beyond the first round. It further held that the amendment created an arbitrary classification between candidates based solely on the location of their MBBS institution, with no rational nexus to the objective of quality medical education. The Court emphasized that Article 14 prohibits such classifications unless they serve a legitimate state interest, which the State failed to demonstrate.
The Verdict
The petitioner won. The Court held that Condition No.5 as amended violates Article 14 and is ultra vires the national NEET-PG framework. The petitioner was directed to be registered for counseling and permitted to participate, subject to fulfillment of other eligibility conditions. The Court barred the declaration of results without its leave.
What This Means For Similar Cases
State-Level Restrictions on NEET-PG Are Invalid
- Practitioners must challenge any state rule that imposes MBBS graduation location as a condition for NEET-PG eligibility.
- The judgment establishes that national entrance exams cannot be subordinated to state-specific eligibility criteria.
- Any future amendment to admission rules must align with the NMC Act and NEET guidelines.
Relaxation Clauses Are Mandatory, Not Discretionary
- When rules contain relaxation clauses triggered by non-availability of preferred candidates, they must be applied in all subsequent rounds.
- Authorities cannot arbitrarily limit the applicability of such clauses after a certain round.
- Legal notices must be issued to state medical boards to ensure compliance with this interpretation.
Equal Access Under Article 14 Is Non-Negotiable
- Discrimination based on the geographical origin of medical education is constitutionally impermissible.
- This precedent applies equally to other states attempting similar restrictions in medical, engineering, or other professional admissions.
- Petitioners in other jurisdictions may now cite this judgment to challenge analogous residency-based barriers.
