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CASE ANALYSIS ON DR. TANVI BEHL V. SHREY GOEL & ORS.: CIVIL APPEAL NO. 9289 OF 2019 / 2025 INSC 125

Selvaprasad. T, LL.M (IPR Law), 3rd Semester, Student at Government Law College Thiruchirappalli, affiliated with Tamil Nadu Dr. Ambedkar Law University, Chennai (India)

Gowthaman. M, Advocate at High court of Madras (India)

The Supreme Court of India, in Dr. Tanvi Behl v. Shrey Goel & Ors., delivered a significant constitutional ruling on whether residence-based or domicile-based reservation in post-graduate medical courses is constitutionally valid. This case is arisen from the Union territory of Chandigarh, where the Government medical college and Hospital reserved all 64 state quota seats either for Institutional based preference or for the person satisfying residential criteria of the Chandigarh. This was challenged before the High court of Punjab and Haryana and High Court held that it unconstitutional on the ground it violated the Article 14 of the Constitution of India. The matter was subsequently referred to the larger bench of Supreme Court after the division bench framed question of law for authoritative determination. A three-Judge Bench comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, S.V.N. Bhatti held that residence-based reservation in PG medical course admission is constitutionally impermissible and violates the right to equality guaranteed under Article 14 of the Constitution. The Court reaffirmed the principles laid down in Jagadish Saran v. Union of India, Dr. Pradeep Jain v. Union of India, and the Constitution Bench decision in Saurabh Chaudri v. Union of India. It also clarified that the concept of provincial or state domicile is alien to the Indian Legal system, as India recognise only one Domicile, which is domicile of India. The court further distinguished between permissible residence-based reservation in MBBS course and impermissible reservation at the PG level, where merit must remain paramount. The ruling strengthened constitutional equality and reaffirms that the national citizenship cannot be subordinated to residence-based preferences in higher medical education.

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Research Paper LawFoyer International Journal of Doctrinal Legal Research (LIJDLR), Volume 4, Issue 2, Page 2758–2772.
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