Locality-based admission rules must have a real nexus to the object of serving residents, or they risk arbitrariness.

A locality-based admission rule was analysed under Article 14 for excluding permanent residents of Ahmedabad who studied in institutions outside the municipal limits. The court reasoned that a distinction based only on the physical location of the school, without a real nexus to the object of serving local residents through merit-based admissions, is artificial and arbitrary. At the same time, the rule was treated as capable of reasonable construction because it was subordinate legislation intended to preserve a substantial reservation for local residents. On that construction, permanent residents of Ahmedabad studying in the Ahmedabad Urban Development Area were included, and the challenge to the rule failed.

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Issues: Whether Rule 7 of the admission rules, which confined the category of "local students" to those who had studied in institutions situated within the municipal limits, was arbitrary and violative of Article 14 of the Constitution of India, and whether the rule could be sustained by a reasonable construction.

Analysis: The classification created by Rule 7 excluded permanent residents of Ahmedabad who had obtained their qualifying education from institutions situated in the adjoining development area, although the stated object of the admission scheme was to cater to the educational needs of Ahmedabad residents and to make merit-based admissions for that local class. A distinction based only on the physical location of the school or college, without reference to residence or any other real connection with the object of the scheme, was held to create an artificial distinction and lacked a rational nexus with the purpose of the rule. At the same time, the existence of the rule was considered important for preserving the local body's legitimate policy of reserving a substantial part of the seats for its own residents, and the rule was treated as subordinate legislation capable of being construed so as to avoid constitutional invalidity.

Conclusion: Rule 7 was not struck down; it was upheld only after being read to include a permanent resident of Ahmedabad who had acquired the requisite qualifications from institutions situated in the Ahmedabad Urban Development Area. The challenge to the rule therefore failed in its ultimate form, and the appeal succeeded.

Ratio Decidendi: A locality-based admission rule is unconstitutional if the classification adopted has no real nexus with the object of serving the local residents, but the rule may be saved by a reasonable construction that preserves its purpose while removing the arbitrary exclusion.

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