In a landmark decision, the Supreme Court overturned a Madhya Pradesh High Court ruling that had denied meritorious reserved category candidates admission into the unreserved (UR) category.
The bench, led by Justice BR Gavai and Justice KV Viswanathan, referenced the Saurav Yadav and Others v. State of Uttar Pradesh case, affirming that candidates from reserved categories such as SC/ST/OBC, who qualify on their own merit, must be considered under the UR quota.
The Court clarified, “A meritorious reserved category candidate entitled to a General category seat based on merit cannot be counted towards the horizontal reservation for their respective reserved category.” This interpretation ensures that such candidates receive their rightful place in the general pool, without being relegated to their reserved categories.
Case Background
The case concerned admissions to MBBS seats, where 5% were reserved for students from Government Schools (GS). Due to a lack of applicants, seats initially allocated to the GS-UR category were transferred to the open category under the Madhya Pradesh Education Admission Rules, 2018.
The appellants, meritorious students from reserved categories who studied in government schools, argued that they should have been allocated the unreserved GS seats before they were moved to the open category. The High Court had dismissed their petitions, prompting an appeal to the Supreme Court.
Legal Arguments and Observations
The appellants contended that the High Court had misapplied the principles established in the Saurav Yadav case. They argued that less meritorious candidates were admitted to the UR-GS seats, while they, despite having higher marks, were denied admission.
The respondents argued for further sub-classifications within the horizontal reservation system, but the Supreme Court found this unsustainable.
Justice BR Gavai, authoring the judgment, stated, “The appellants, who were more meritorious than the admitted UR-GS candidates, were unjustly denied admission due to an erroneous application of horizontal and vertical reservation principles.”
The Court concluded that the refusal to admit meritorious reserved category candidates to unreserved seats was contrary to established law. It directed that the appellants be admitted to the UR-GS seats in the next academic session (2024-25), thus allowing the appeal.
