Writ petition filed by the All India Backward Classes Federation, challenging specific rules concerning admissions into postgraduate medical courses in Andhra Pradesh and Telangana. The petitioner, a former High Court judge, argued that the existing rules in Telangana illegally reduce reserved category seats by counting meritorious reserved candidates (MRCs) against reserved quotas even when they qualify for open seats. The Court examined precedents regarding reservation policies, noting that MRCs should typically be considered open category candidates. However, the Supreme Court ultimately declined to rule on the abstract question presented in the Public Interest Litigation, stating that such complex issues require consideration of specific individual grievances and cannot be decided without hearing from all potentially affected parties.
Constitution of India, Article 31 – Andhra Pradesh Medical Colleges (Admission into Post Graduate Medical Courses) Rules, 1997, clauses (viii) and (ix) of Rule II – Telangana Medical Colleges (Admission into Post Graduate Medical Courses) Rules, 2017, clauses (viii) and (ix) of Rule II – Public Interest Litigation – Admission to medical course – Challenge to validity of clauses (viii) and (ix) of Rule II of the Rules, 1997 and 2017 – Admission – Post Graduate Medical Courses – Reservation – Contention that the Meritorious Reserved Candidates who are entitled to be admitted against a reserved seat on their own merits have to be treated as open category candidates for the purpose of reservation so that another reserved category candidate is not deprived of his claim to the admission – It is submitted that due to Rules which are continued by the State of Telangana, if a reserved category candidate, who is entitled to get admission in ‘A’ Category on his own merits, does not accept the same and decides to take admission in ‘B’ Category, where he is entitled to be admitted only against a reserved seat, even in such a case the seat in ‘A’ Category should be filled in by a reserved category candidate – He submits that if that is not done, there will be a reduction of the reserved category seats – Held that the issues involved with regard to the reliefs sought by the petitioner cannot be considered unless the Court considers specific cases of grievances raised by any particular individuals.
The question involved in the present case would require consideration of various complexities on account of the availability of opportunity to an MRC to slide to any super- specialties or non-availability of such an opportunity and restricting it only to sliding to the same speciality from an open category to a reserved category and the resultant effect thereon on the position of the reservation vis-a-vis the position of the seats available to an open category as against the seats available to a reserved category – No doubt that the concern of the petitioner for maintaining the percentage of reservation of seats in medical specialities for the reserved category candidates could be genuine but unless the specific cases of the candidates arise for consideration before the Court, such an issue cannot be decided in abstract – Furthermore, such an issue cannot be decided without hearing other candidates who may be adversely affected by any such adjudication – Held that such a question cannot be considered in a Public Interest Litigation – Writ petition disposed of by observing that whenever any such issue arises for consideration before any of the High Courts, the High Courts would consider the same on its individual merits, in accordance with law, as laid down by this Court.
(Para 5, 15 to 18)
Justice V.Eswaraiah (Retd.) V. Union Of India
Supreme Court: 2025 INSC 342: (DoJ 25-02-2025)
