1984 (7) TMI 395 - SC - Indian Laws

Invalidation of Reservation Quota for Rural Candidates in Medical Admissions

The Court held that the reservation of 25 seats for candidates from rural areas for admission to the MBBS/BDS Course was constitutionally invalid. The ... - Issues Involved:1. Validity and legality of reservation of 25 seats for candidates from rural areas for admission to MBBS/BDS Course.2. Whether the classification between students educated in urban schools and common rural schools is based on intelligible differentia with a rational nexus to the object sought to be achieved.3. Whether the reservation is sustainable under Articles 14, 15(4), and 29(2) of the Constitution.Issue-wise Detailed Analysis:1. Validity and legality of reservation of 25 seats for candidates from rural areas for admission to MBBS/BDS Course:The petitioners challenged the reservation of 25 seats for candidates from rural areas as being violative of Articles 14, 15(4), and 29(2) of the Constitution. They argued that the classification is arbitrary, unintelligible, and unrelated to the objects sought to be achieved. The respondents contended that the classification and consequent reservation are valid under Article 14 of the Constitution, aiming to correct regional imbalances and provide opportunities to students from disadvantaged rural schools.2. Whether the classification between students educated in urban schools and common rural schools is based on intelligible differentia with a rational nexus to the object sought to be achieved:The Court examined whether the classification based on candidates coming from rural areas against urban areas satisfies the twin tests of permissible classification under Article 14. The Court noted that all students seeking admission to the medical college must have studied up to the 12th standard, meaning that even candidates from common rural schools would have joined urban schools for the last four years. The Court found that the education from Class I to VIII is of a general nature and does not equip a student for admission to a medical college. Consequently, the classification based on education from Class I to VIII in common rural schools is arbitrary and irrational, failing to provide intelligible differentia and having no rational nexus to the object sought to be achieved.3. Whether the reservation is sustainable under Articles 14, 15(4), and 29(2) of the Constitution:The respondents did not attempt to sustain the reservation under Article 15(4), which allows special provisions for socially and educationally backward classes or scheduled castes and tribes. Instead, they argued that the reservation is valid under Article 14. The Court referred to the decision in State of U.P. v. Pradeep Tandon, which struck down similar reservations for candidates from rural areas, holding that such reservations cannot be sustained on the ground that rural areas represent socially and educationally backward classes. The Court concluded that the classification in the present case is similarly invalid, as it is not based on intelligible differentia and has no rational nexus to the object sought to be achieved.Conclusion:The Court held that the classification and reservation of 25 seats for candidates from rural areas for admission to the MBBS/BDS Course are constitutionally invalid. The classification is arbitrary and irrational, failing to satisfy the twin tests of permissible classification under Article 14. The reservation is not sustainable under Articles 14, 15(4), and 29(2) of the Constitution. Consequently, the Court quashed the reservation and directed the respondents to admit students based on the general merit list for the year 1982.