“Restricting the Migration of the Meritorious Reserved Category Candidates to the Unreserved Seats is Totally Unsustainable:” Supreme Court

While hearing the Ramnaresh @ Rinku Kushwah and Others vs. State of Madhya Pradesh and Others case on August 20, 2024, the Supreme Court (SC) of India set aside the order of the Madhya Pradesh High Court (HC) refusing to allow admission of the meritorious reserved category candidates to the Unreserved category (UR Category). The SC bench of Justice BR Gavai and Justice KV Viswanathan said restricting the migration of meritorious reserved category candidates to the UR seats is unsustainable. It said, “...a meritorious reserved category candidate who is entitled to the General category of the…horizontal reservation on his own merit, will have to be allotted a seat from the said General category of the horizontal reservation. Meaning thereby such a candidate cannot be counted in a horizontal seat reserved for the category of vertical reservation like SC/ST.”

During the proceedings, the SC bench observed “Undisputedly, the appellants who were meritorious and who could have been admitted against the UR-GS category were denied admission on account of an erroneous application of the methodology in applying the horizontal and vertical reservation. It is also not in dispute that many of the students, who secured much less marks than the appellants, have been admitted against the UR-GS seats. This is totally in contravention of the law laid down by this Court in the cases of Saurav Yadav and Sadhana Singh Dangi.” It added, “...restricting the migration of the meritorious reserved category candidates to the unreserved seats is totally unsustainable. In view of the law laid down by this Court, the meritorious candidates belonging to SC/ST/OBC, who on their own merit, were entitled to be selected against the UR-GS quota, have been denied the seats against the open seats in the GS quota.”

In this case, the writ petitioners (appellant) challenged the decision of the Respondent-Department of Medical Education of not allotting MBBS Unreserved (UR) Category Government School (GS) quota seats to the meritorious reserved candidates, who had passed from the Government Schools. It had also prayed for a direction to the Respondent-Department to allot the MBBS seats of Unreserved Category Government School quota to the appellants. Writ petitioners before the High Court have approached the Supreme Court by way of appeals arising out of a Special Leave Petition (SLP). Being aggrieved by the fact that the vacant seats were going to be released to the unreserved category, the aforesaid writ petitions were filed by the appellants before the High Court, where it was prayed that the meritorious students of the reserved category who have studied in Government Schools must be allotted MBBS seats of unreserved category government school quota before they are released to the open category. 

After hearing the contentions of both parties, the bench said, “We, therefore, find that as held by this Court in the case of S. Krishna Sradha…, it will be appropriate to issue directions to the respondents to admit the appellants in the next Academic Session 2024-25 against the UR-GS seats. Vide order dated 12th August 2024, we have already directed 7 seats to be kept vacant in the event the appellants succeed. The appellants can be very well accommodated against the said seats.” Thus, the top court quashed and set aside the impugned judgments passed by the Madhya Pradesh HC and directed the respondents to admit the appellants in the next Academic Session for the MBBS Course against seats reserved for the UR-GS Category.