Home > Recent Judgements >Merit-Based Selection And Vertical Reservation Quotas: The Legal Position On Candidates Securing Open Category Seats
August 28, 2024
FACT
In the between Ramnaresh @ Rinku Kushwah and Others v. State of Madhya Pradesh and Others, The present appeals challenge the judgments and orders dated 22nd December 2023 and 12th January 2024 passed by the High Court of Madhya Pradesh at Gwalior in Writ Petition Nos. 23998 and 23437 of 2023, and 23060 of 2023 respectively. The writ petitioners (appellants herein) had filed these writ petitions to challenge decision of the Respondent-Department of Medical Education not allotting MBBS Unreserved (UR) Category Government School (GS) quota seats to meritorious reserved candidates who had passed from Government Schools. The appellants had also prayed for a direction to Respondent-Department to allot MBBS seats of Unreserved Category Government School quota to them.
ISSUE
- Whether Validity of Sub-Classification under Horizontal Reservation.
- Whether Right to Admission under Unreserved Government School (UR-GS) Quota.
JUDGEMENT
This was because the court recognized that the appellants were meritorious and they ought to have been considered for UR-GS seats. It was held that the mode adopted by the state government in further sub-classifying horizontal reservations, so as not to allow meritorious reserved category students compete within UR-GS category, was wrong and against legal precedents as set out in cases like Saurav Yadav v. State of Uttar Pradesh. Those two appeals were allowed thereby setting aside judgment of High Court.
RELIEF GRANTED
The academic session for 2023-24 had already ended, the court directed that the appellants be admitted in the next academic session (2024-25) against the UR-GS seats.
The court also overturned the earlier High Court judgments that had dismissed the appellants’ petitions.
ANALYSIS
The appellants, in their favour, had the previous High Court judgments set aside by the court.
Recognition of Merit: In terms of merit, it acknowledged and held that the appellants should have been considered for UR-GS seats. It was an important aspect as it recognized that horizontal reservation should compromise merit.
Illegality of Further Sub-Classification: According to the judgment, further sub-classification by the state through which meritorious reserved category students could not compete for UR-GS seats is legally flawed. This has been derived from Saurav Yadav v. State of Uttar Pradesh where it was opined that even meritorious reserved category candidates should be allowed to contest unreserved seats under horizontal reservations.
Relief Granted: For example, although academic year 2023-24 had already ended, the court ordered admission of the plaintiffs into next session (2024-25) against UR-GS seats. The ruling emphasizes a commitment by judicial officers to correct injustices, even if they were not immediate.
Overturning of High Court Judgments: The petitioners’ pleas which were dismissed in previous judgments of the High Court have been overruled by the Supreme Court. This is a landmark that will be useful in such matters as merit cum reservations.
CONCLUSION
This decision reiterates that vertical quotas should not erode the quality of candidates, especially for unreserved category seats. It is also an elucidation on horizontal reservations within sub-categories, confirming its continued significance to competition based on merits. The judgment can have significant implications on how states implement horizontal reservations across different sectors including education and employment.
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