Mentor’s Comment: UPSC mains have always focused on the Welfare State, primary health structure (2021), and Public health system (2015).

The Supreme Court’s judgment in Dr. Tanvi Behl vs Shrey Goyal (2025), striking down domicile-based reservations in post-graduate medical admissions, changes India’s medical education policy. While promoting merit, it overlooks how these reservations support State public health needs and may discourage States from investing in government medical colleges, weakening their healthcare systems.

Today’s editorial discusses domicile-based reservations, which is useful for writing answers in UPSC Mains GS Paper 2 on Governance, especially regarding State policies and public health challenges.

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Let’s learn!

Why in the News?

The ruling that ended domicile-based reservations in post-graduate medical admissions ignores the practical challenges of managing public health.

What are the key arguments made by the Supreme Court in striking down domicile-based reservations?

• Violation of Article 14 (Right to Equality): The Court held that domicile-based reservations in post-graduate medical admissions violate Article 14 of the Constitution, which guarantees equality before the law. Example: It argued that restricting access to medical seats based on domicile status is discriminatory against equally qualified non-local candidates.
• Primacy of Meritocracy in Higher Education: The judgment emphasized that merit should be the primary criterion for post-graduate medical admissions to ensure the best candidates receive specialist training. Example: It relied on Pradeep Jain vs Union of India (1984), where the Court discouraged domicile-based quotas, stating that such policies dilute academic standards in advanced medical training.
• Uniform and Centralized Medical Education Framework: The Court favored a national, merit-based system to maintain uniformity in medical admissions across States and prevent fragmentation. Example: It pointed to central institutions like AIIMS and PGIMER, which follow a centralized selection process without domicile reservations, ensuring open competition for all candidates.

Why is domicile-based reservation considered crucial for State-level?

• Retention of Specialist Doctors in Public Health Systems: Domicile quotas ensure that medical graduates trained in State institutions are more likely to serve within the State, addressing local health-care needs. Example: States with severe specialist shortages (e.g., rural Bihar or Odisha) rely on domicile-based reservations to retain medical professionals and improve health outcomes.
• Alignment of State Investment with Local Workforce Needs: States invest substantial resources in medical education and expect returns through a local medical workforce. Domicile quotas ensure these investments benefit the State’s health infrastructure. Example: Tamil Nadu links domicile-based quotas to mandatory public service, ensuring that doctors trained using State funds serve in government hospitals.
• Addressing Regional Health Disparities: Domicile reservations help in reducing regional imbalances by ensuring that underserved areas have access to medical specialists who understand local challenges. Example: Northeastern States with limited access to advanced medical care use domicile quotas to maintain a local pool of doctors familiar with tribal and rural health needs.
• Predictable Medical Workforce Supply: States depend on domicile quotas to create a steady pipeline of medical specialists who can fulfill long-term public health needs. Example: Maharashtra implements domicile-based reservations to ensure consistent recruitment for rural health centers and district hospitals.
• Incentivizing State Investment in Medical Education: If States cannot ensure that their medical graduates remain local, they may reduce funding for medical colleges, weakening health infrastructure. Example: Without domicile quotas, smaller States like Goa risk losing locally trained doctors to other regions, discouraging future investment in medical education.

How does the ruling impact State incentives to invest in government medical colleges and public health infrastructure?

• Reduced Motivation to Fund Medical Education: Without domicile-based reservations, States cannot ensure that doctors trained in government-funded colleges will stay and serve locally. This may discourage future investments in medical education. Example: Odisha may be less inclined to invest in new medical colleges if graduates move to other States for better opportunities.
• Weaker Public Health Infrastructure: States depend on locally trained doctors to staff public hospitals. Without a guaranteed local workforce, rural and underserved areas may face doctor shortages, weakening health services. Example: Bihar, already struggling with a lack of specialists, could face further shortages in district hospitals due to reduced local retention.
• Increased Dependence on External Recruitment: The ruling forces States to rely on recruiting doctors from outside, which can be costly, inefficient, and unpredictable, especially in remote regions. Example: Himachal Pradesh may need to import specialists, increasing costs and reducing long-term staffing stability in rural clinics.
• Discouragement of Regional Policy Innovation: States using service-linked quotas to address local health needs lose a valuable tool to customize their medical education policies. Example: Tamil Nadu’s model, which ties post-graduate seats to public service, could be undermined, reducing the State’s ability to ensure healthcare delivery.
• Widening Regional Health Inequalities: States with fewer resources will struggle to compete with wealthier regions in attracting and retaining medical professionals, increasing healthcare gaps. Example: Northeastern States like Assam may face a brain drain, making it harder to deliver essential medical care in rural areas.

Way forward: 

• Balanced Policy Framework: Introduce a hybrid model combining merit-based admissions with incentives (e.g., service bonds or rural postings) to retain doctors in underserved areas while upholding constitutional equality.
• Strengthening National and State Collaboration: Foster State-Centre cooperation to create region-specific policies under the National Medical Commission (NMC) that address local health needs without violating merit-based norms.

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