Reservation in medical recruitment and admissions upheld as constitutionally valid, with roster, carry-forward and backlog vacancies maintained.

Reservation for Scheduled Castes and Scheduled Tribes in teaching recruitment was upheld where Assistant Professor posts in different disciplines carried the same designation and pay scale; roster rotation and carry-forward vacancies could operate in a single post cadre, and general candidates had no right to demand de-reservation absent approval. Reservation in postgraduate, doctoral, speciality and super-speciality medical admissions was also sustained because it affects only entry and does not, by itself, dilute merit or academic excellence, which remain governed by the same standards after admission. The Institute could not unilaterally de-reserve backlog vacancies or throw them open to general candidates without following the governing policy and procedure.

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Issues: (i) whether reservation in recruitment to the post of Assistant Professor in different disciplines of the Institute, including application of roster and carry-forward vacancies in a single post cadre, was constitutionally valid; (ii) whether reservation in admission to postgraduate, doctoral, speciality and super-speciality courses in the Institute was unconstitutional on the ground of impairment of merit and excellence; (iii) whether the Institute could treat reserved vacancies as de-reserved or direct their being thrown open to general candidates.

Issue (i): whether reservation in recruitment to the post of Assistant Professor in different disciplines of the Institute, including application of roster and carry-forward vacancies in a single post cadre, was constitutionally valid.

Analysis: The Institute was bound by the statutory scheme and the applicable reservation policy. Regulation 32(2) required reservation for Scheduled Castes and Scheduled Tribes in vacancies in teaching faculty, and the posts of Assistant Professor in different disciplines, though separate in specialty, carried the same designation and pay scale. The Court applied the settled principle that reservation by rotation and roster can operate even in a single post cadre through successive vacancies treated as roster vacancies, and that clubbing posts carrying the same scale is constitutionally permissible. The Court also held that general candidates had no right to insist on de-reservation where the Government had not sanctioned it and the backlog vacancies were to be filled by the reserved category through special recruitment and carry-forward.

Conclusion: The reservation in recruitment to Assistant Professor posts, with roster and carry-forward, was valid and constitutional, and the challenge failed.

Issue (ii): whether reservation in admission to postgraduate, doctoral, speciality and super-speciality courses in the Institute was unconstitutional on the ground of impairment of merit and excellence.

Analysis: The Court held that protective reservation in higher medical education does not by itself destroy merit or excellence, because admitted students are required to undergo the same course, examination standard and qualifying requirements. Reservation operates only as a facility at the stage of entry and does not dilute the academic standard applicable to all students. The Court distinguished cases dealing with domicile or institutional preference and reaffirmed that Articles 15(4) and the constitutional scheme permit reservation for socially disadvantaged classes even in specialised medical education, subject to the same academic threshold after admission.

Conclusion: Reservation in postgraduate and super-speciality admissions was upheld as constitutionally valid.

Issue (iii): whether the Institute could treat reserved vacancies as de-reserved or direct their being thrown open to general candidates.

Analysis: The Court held that de-reservation is governed by the Government's policy and prescribed procedure, and the Institute could not unilaterally de-reserve reserved vacancies. General candidates had no enforceable right to seek a mandamus compelling de-reservation or to insist that backlog reserved vacancies be filled by them. The Court also held that the constitutional and executive policy required faithful implementation of reservation, including for backlog vacancies, unless de-reservation was validly authorised in accordance with the governing procedure.

Conclusion: No direction could be issued to de-reserve the posts or to fill reserved vacancies with general candidates.

Final Conclusion: The appeals succeeded and the constitutional validity of reservation in both recruitment and admissions within the Institute was affirmed, with the consequential challenge to withdrawal of reservation also rejected.

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