Reservation in postgraduate medical admissions is constitutionally permissible, subject to standards and the State's legislative competence.

Article 15(4) was read broadly to permit reservation of seats in educational admissions, including postgraduate medical courses, and not merely preferences or concessions. The challenge that reservation was anti-merit was rejected because reservation operates at entry stage only, while qualifying standards remain applicable for completion of the course, and academic marks were not treated as a reliable test of professional efficiency. The medical council framework was held to regulate standards of medical education, not to bar State reservation policy, and the State was found competent to prescribe reservation in postgraduate admissions under Entry 25 of List III, with Entry 66 of List I confined to standards and coordination.

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Issues: (i) whether reservations in postgraduate medical courses could be made under Article 15(4) of the Constitution of India; (ii) whether such reservations were impermissible as being anti-merit or detrimental to societal interests; (iii) whether the Medical Council regulations excluded State power to provide such reservations; and (iv) whether the State had competence to prescribe reservation policy in admissions to postgraduate medical courses in view of Entry 66 of List I.

Issue (i): whether reservations in postgraduate medical courses could be made under Article 15(4) of the Constitution of India.

Analysis: The expression "any special provision" in Article 15(4) was held to be wide enough to include reservation of seats in educational institutions. The power to make such special provision was treated as a constitutional power long recognised in the context of educational admissions. The Court rejected the contention that Article 15(4) permits only preferences or concessions and not reservation.

Conclusion: Reservations in postgraduate medical courses are permissible under Article 15(4) of the Constitution of India.

Issue (ii): whether such reservations were impermissible as being anti-merit or detrimental to societal interests.

Analysis: The Court held that reservation does not mean the abandonment of merit. It operates only at the stage of entry, while the same qualifying standards apply at the stage of passing and completion. The reasoning in earlier decisions on merit and equality was read as recognising that reservations may involve some adjustment at the entry stage but are a constitutionally accepted means of advancing social justice. The Court also held that academic performance is not a certain indicator of professional efficiency.

Conclusion: The challenge based on anti-merit and detriment to society was rejected.

Issue (iii): whether the Medical Council regulations excluded State power to provide such reservations.

Analysis: The Indian Medical Council Act, 1956 was held to concern standards of medical education and training, not admission policy. The regulations requiring selection on merit were treated as advisory and not as a binding prohibition on reservations under Article 15(4). The Court further held that the later recommendations had not become operative regulations and therefore could not control State admissions policy.

Conclusion: The Medical Council regulations did not bar the State from providing reservation in postgraduate admissions.

Issue (iv): whether the State had competence to prescribe reservation policy in admissions to postgraduate medical courses in view of Entry 66 of List I.

Analysis: Applying the doctrine of pith and substance and harmonious construction of the constitutional entries, the Court held that regulation of admissions to postgraduate medical courses lies within Entry 25 of List III and is not taken away by Entry 66 of List I, which concerns coordination and determination of standards. The State was therefore competent to regulate admissions, so long as the standards fixed by the medical body were not undermined.

Conclusion: The State had competence to provide for reservations in postgraduate medical admissions.

Final Conclusion: The constitutional and statutory challenges to the reservation policy failed, and the reservation provided for postgraduate medical admissions was upheld.

Ratio Decidendi: Article 15(4) authorises reservation in educational admissions as a special provision for advancement of backward classes, and such reservation in postgraduate medical courses is valid so long as it does not negate the standards of the course or exceed the State's competence under the constitutional allocation of legislative power.

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