The Chhattisgarh High Court has decisively clarified that provisional admissions in postgraduate medical courses do not create indefeasible rights, even when candidates have paid fees and been allotted seats. The court upheld the state’s authority to amend admission rules to comply with the Supreme Court’s mandate in Dr. Tanvi Behl v. Shrey Goel, reinforcing that institutional preference must not eclipse merit and that any reservation must remain within constitutionally permissible limits.
Background & Facts
The Dispute
The petitioner, Dr. Samriddhi Dubey, challenged an amendment to Rule 11 of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, dated 22.01.2026. This amendment restructured the seat matrix to distinguish between "institutional preference" seats and "open category" seats, effectively cancelling all admissions granted under the earlier version of the rules dated 01.12.2025. The petitioner had been provisionally admitted under the prior scheme and sought to protect her seat.
Procedural History
- 06.11.2025: Chhattisgarh Medical Post Graduate Admission Rules, 2025, came into effect with institutional reservation norms.
- 20.11.2025: A coordinate Bench of the High Court, in WPC No. 5937/2025, quashed Rule 11(a) and (b) as violative of Article 14, directing the State not to discriminate based on institutional categories.
- 16.01.2026: The State filed a clarification application (MCC No. 40/2026), which was disposed of with directions to permit limited institutional preference, consistent with Dr. Tanvi Behl.
- 01.12.2025: The State issued a revised notification implementing the 20.11.2025 order, conducted two rounds of counselling, and granted provisional admissions, including to the petitioner.
- 22.01.2026: The State issued a new amendment to Rule 11, introducing a 50% "open category" for non-institutional candidates and cancelling all prior allotments.
- 23.01.2026: A clarification was issued affirming that "open category" seats would be filled strictly on merit, without institutional bias.
- 27.01.2026: The same High Court, in Anushka Yadav v. State of Chhattisgarh, dismissed a nearly identical challenge to the 22.01.2026 amendment.
Relief Sought
The petitioner sought quashing of the 22.01.2026 amendment, declaration of its unconstitutionality under Article 14, and protection of her provisional admission. She argued that the State was estopped from altering rules after substantial completion of the admission process.
The Legal Issue
The central question was whether provisional admissions granted under a rule later amended to conform with constitutional mandates can create vested or indefeasible rights, and whether the State’s amendment to Rule 11 constitutes a colourable exercise of power or arbitrary discrimination under Article 14.
Arguments Presented
For the Petitioner
The petitioner relied on the doctrine of legitimate expectation and estoppel, arguing that the State had acted upon the 01.12.2025 amendment, conducted counselling, and granted admissions, thereby creating a settled expectation. She cited Dr. Tanvi Behl to contend that the 22.01.2026 amendment resurrected institutional preference under the guise of an "open category," violating the Supreme Court’s mandate that a portion of seats must remain truly open. She further argued that cancelling admissions mid-process was procedurally unfair and violated Article 14.
For the Respondent
The State contended that the 22.01.2026 amendment was a necessary corrective measure to align with Dr. Tanvi Behl and the clarificatory order in MCC No. 40/2026. It emphasized that admissions in public education are inherently provisional and subject to judicial and statutory review. The State relied on Anushka Yadav v. State of Chhattisgarh (27.01.2026), where the same issue was decided against the petitioner’s position, and argued that judicial discipline required adherence to its own binding precedent.
The Court's Analysis
The Court undertook a rigorous examination of the constitutional framework governing medical admissions. It reaffirmed the holding in Dr. Tanvi Behl that residence-based reservation is impermissible in PG medical courses, but limited institutional preference is permissible - provided it does not undermine merit. The Court noted that the 22.01.2026 amendment explicitly reserved 50% of seats for institutional candidates and the remaining 50% as an "open category" filled strictly on merit, thereby complying with the Supreme Court’s directive.
"The State has acted within its constitutional and statutory domain to ensure that admissions to Post Graduate Medical Courses are made strictly in accordance with settled legal principles and constitutional mandates."
The Court rejected the petitioner’s claim of vested rights, holding that provisional admissions are conditional and subject to change when governing rules are found inconsistent with constitutional norms. It emphasized that the petitioner participated in the process with full knowledge of pending litigation and the possibility of rule amendments. The Court further held that the cancellation of prior allotments was not arbitrary but a necessary administrative consequence of restructuring the reservation matrix to eliminate unconstitutional discrimination.
The Court also distinguished the petitioner’s reliance on estoppel, noting that the State cannot be estopped from correcting constitutional violations, even if done after partial implementation. The clarification issued on 23.01.2026, affirming merit-based allocation in the "open category," demonstrated good faith and compliance, negating any allegation of mala fides.
The Verdict
The petitioner’s writ petition was dismissed. The Court held that provisional admissions do not create indefeasible rights and that the State’s amendment to Rule 11 was constitutionally valid, as it brought the admission process into conformity with Dr. Tanvi Behl. All prior allotments were lawfully cancelled, and the new seat matrix was upheld as compliant with Article 14.
What This Means For Similar Cases
Provisional Admissions Are Not Vested Rights
- Practitioners must advise clients that admission to public educational institutions, especially in competitive fields like medicine, is always provisional until finalized under valid rules.
- Candidates who rely on provisional allotments must be informed of pending litigation or rule amendments that may affect their status.
- Courts will not protect individual interests where the underlying process violates constitutional mandates.
Institutional Preference Must Be Transparent and Merit-Conforming
- Any institutional preference must be clearly demarcated and limited to a reasonable percentage.
- "Open category" seats must be filled strictly on inter-se merit, without hidden institutional bias.
- Amendments to reservation matrices are permissible if they correct constitutional infirmities, even after partial implementation.
Judicial Precedent Is Binding Across Identical Challenges
- Writ petitions raising identical legal and factual issues will be dismissed on grounds of judicial discipline and comity.
- Practitioners must conduct thorough precedent checks before filing repetitive petitions.
- Courts will refuse to entertain successive petitions on settled issues to prevent multiplicity and ensure finality in admissions.
