Regional reservation in medical admissions needs real backwardness data; unsupported classification and quota fail constitutional scrutiny.

A reservation for regional imbalance in medical admissions was held invalid because the classification lacked disclosed, relevant material showing a rational and intelligible basis of social and educational backwardness, so the quota was quashed and those seats directed to be filled on open merit. The challenge based on viva voce weightage and brief interviews was not accepted as a ground to invalidate the selections, although the method was criticized as requiring revision. Allegations of an improperly composed Selection Committee, favouritism, and non-compliance with Medical Council Regulations were also rejected on the material before the Court.

---

---

Issues: (i) whether the reservation made for rectifying regional imbalances by identifying large numbers of villages as socially and educationally backward was constitutionally valid; (ii) whether allocation of 30% marks to viva voce and the manner of interview could invalidate the selection; (iii) whether the varying composition of the Selection Committee and allegations of favouritism vitiated the admissions; (iv) whether the challenged admissions in the Jammu selection were contrary to the Indian Medical Council Regulations.

Issue (i): whether the reservation made for rectifying regional imbalances by identifying large numbers of villages as socially and educationally backward was constitutionally valid.

Analysis: The basis of the classification was not supported by disclosed material demonstrating a rational and intelligible foundation. A large number of villages, towns and even parts of urban areas were included without adequate data showing social and educational backwardness. A reservation for rural or broadly defined regional areas cannot stand unless supported by relevant considerations and a valid classification. The asserted objective of correcting regional imbalance did not, on the material before the Court, satisfy the constitutional requirement applicable to such reservations.

Conclusion: The classification and the quota made for rectifying regional imbalances were invalid and the admissions made under that head were liable to be quashed.

Issue (ii): whether allocation of 30% marks to viva voce and the manner of interview could invalidate the selection.

Analysis: The allocation to viva voce was high and the interview time was short, but the selection process had already been undertaken before the later clear pronouncement treating a higher interview weightage as constitutionally suspect. On the record, the Court was not prepared to strike down the selections solely on this ground, though it indicated that the ratio of marks required reconsideration and that interviews should receive adequate time and care.

Conclusion: The selections were not set aside on the ground of viva voce weightage or the length of interview, though the method was disapproved as needing revision.

Issue (iii): whether the varying composition of the Selection Committee and allegations of favouritism vitiated the admissions.

Analysis: The slight delay in one member joining, the temporary absence of another, and the alleged favouritism were not shown by reliable material to have materially affected the proceedings. The allegations of preferential treatment were largely vague, late, or unsupported by adequate opportunity for rebuttal, and the composition of the Committee by itself was not unlawful merely because a Government official participated.

Conclusion: The Committee's proceedings were not vitiated and the allegations of favouritism were rejected.

Issue (iv): whether the challenged admissions in the Jammu selection were contrary to the Indian Medical Council Regulations.

Analysis: The Court declined to give a final ruling on the full reach and enforceability of the Regulations in the absence of the Council as a party. On the material before it, it was not satisfied that the introduction of a competitive objective test, the allocation of marks between components, or the presence of a Government official on the Committee rendered the selections unlawful.

Conclusion: The challenge based on the Regulations failed.

Final Conclusion: The admissions made under the quota for rectifying regional imbalances were quashed and those seats were directed to be filled on open merit, while the remaining challenges to the selection process were rejected or not accepted as grounds for invalidating the selections.

Ratio Decidendi: A reservation or classification for admission must rest on disclosed, relevant and intelligible material showing a constitutionally permissible basis of backwardness or imbalance; a vague or unsupported regional classification is arbitrary and invalid.

---