The Madhya Pradesh High Court has struck down a state government amendment that granted 100% institutional preference for postgraduate (PG) medical seats in private colleges to students who completed their MBBS in Madhya Pradesh. The court ruled this quota unconstitutional, violating the Supreme Court’s established 50% reservation cap.
Court’s Ruling and Reasoning
A division bench, comprising Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf, deemed the state government’s amendment notification unlawful. The bench stated that any form of reservation in private colleges exceeding 50% is impermissible under law, directly contravening judgments from the Supreme Court.
The court explicitly noted that the amended rule, dated September 3, 2025 , created a 100% reservation for all PG seats in private medical colleges. This comprehensive reservation, applied through various categories, was found to be unconstitutional, as per prevailing Supreme Court precedents that mandate a ceiling on such quotas.
Principle of the 50% Cap
The Supreme Court has consistently held that reservations in educational institutions, including medical colleges, cannot exceed 50%. This cap aims to balance affirmative action with the principle of merit and equal opportunity for all candidates. Allowing a 100% reservation, even through different preference categories, effectively closes off all seats to those outside the specified criteria, undermining the competitive nature of admissions and potentially excluding deserving candidates from other regions or backgrounds.
Details of the Quashed Quota
A key eligibility requirement for these PG seats was that candidates must have obtained their MBBS degree from a medical college within Madhya Pradesh. The court observed that of the 1,026 total PG seats in private medical colleges, 15% were earmarked for the NRI quota, 30% for in-service candidates, and the remaining seats were to be allotted based on institutional preference. This tiered structure, when combined, resulted in all 100% of the PG seats being reserved in one category or another, exclusively favoring candidates with an MBBS degree from within the state.
State’s Defense and Court’s Rebuttal
The state government defended its amendment, arguing it constituted a sequential preference rather than an outright 100% institutional reservation. The state asserted its intention to retain and advance medical talent trained within the region, claiming that Madhya Pradesh-trained medical students were better suited for the local healthcare landscape and its specific needs.
However, petitioners countered that the limited number of available PG seats would likely be entirely filled through this system of reservation and preference, effectively shutting out other eligible candidates. The court sided with the petitioners’ submission, concluding that all seats were highly probable to be filled in the very first round of counselling itself.
Impact on Counselling Process
The amended rules also stipulated strict conditions for counselling. Candidates who did not register for MP NEET PG Round 1 counselling were rendered ineligible for participation in subsequent counselling rounds. Critically, only students who completed their MBBS from colleges located within Madhya Pradesh were permitted to take part in the initial round of counselling.
An exception existed, allowing the 100% restriction to be lifted in the second round if a sufficient number of students were unavailable in the first. However, the court found this scenario highly improbable. Given the intense competition and limited availability of PG medical seats, the court anticipated that all seats would be filled during the initial round, thereby rendering the supposed second-round flexibility largely ineffective.
This ruling reinforces the constitutional mandate for fair and equitable access to higher medical education. It ensures that private medical colleges in Madhya Pradesh must adhere to the 50% cap on reserved PG medical seats, promoting a broader and more merit-based admission process for all eligible candidates.