ValkyaEditorial
High Court

Dr. Samriddhi Dubey v. State of Chhattisgarh (2025): institution-based PG-medical preference struck down

A Division Bench of the Chhattisgarh High Court struck down Rule 11(a) and Rule 11(b) of the State's 2025 PG-medical admission rules, which had reserved State-quota postgraduate seats for candidates who obtained their MBBS from a Chhattisgarh medical college. The Court held the institution-based preference to be a de-facto reservation, ultra vires and violative of Article 14. A digest of the facts, the holding, and the Supreme Court line it applied.

Valkya Editorial· Legal Intelligence··7 min read
Court
High Court of Chhattisgarh
Citation
Dr. Samriddhi Dubey v. State of Chhattisgarh, 2025:CGHC:56543-DB
Neutral citation
2025:CGHC:56543-DB
Bench
Ramesh Sinha, CJ., Bibhu Datta Guru, J.
Decided
20 November 2025
Provisions discussed

Dr. Samriddhi Dubey v. State of Chhattisgarh belongs to a small group of recent High Court decisions that have applied a clear principle from the Supreme Court to the granular machinery of State admission rules. The dispute was about a single eligibility filter in a set of postgraduate medical admission rules — but the Court's answer reached the constitutional core of how a State may, and may not, prefer its own candidates for professional-course seats. Decided on 20 November 2025 by a Division Bench of Ramesh Sinha, C.J., and Bibhu Datta Guru, J., the judgment struck down the offending rules and reaffirmed that equality under Article 14 bars backdoor preferences built on where a candidate studied.

The facts in brief

The petitioner, Dr. Samriddhi Dubey, is a permanent resident of Chhattisgarh who completed her schooling in Bilaspur. She earned her MBBS from a medical college in Tamil Nadu, having secured that seat through All-India NEET (UG) counselling, and she holds registration with both the Tamil Nadu and the Chhattisgarh Medical Councils. She then appeared in NEET-PG 2025, seeking a postgraduate seat in her home State.

Her path back to Chhattisgarh, however, ran into a rule. She challenged Rule 11(a) and Rule 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025. Rule 11(a) provided that State-quota postgraduate seats would be filled first by candidates who had obtained their MBBS from a medical college situated within Chhattisgarh (along with serving candidates). Rule 11(b) provided that the remaining seats would go to candidates who had obtained their MBBS outside Chhattisgarh but were natives of the State. The effect, for someone in Dr. Dubey's position — a native of Chhattisgarh who had studied her MBBS elsewhere through an all-India process — was to push her to the back of the queue, behind candidates whose only distinguishing feature was the location of the college that conferred their undergraduate degree.

The questions

At the level of the rules, the question was narrow: did Rule 11(a) and Rule 11(b) lawfully prioritise candidates by reference to the State in which they had obtained their MBBS? Answering that required the Court to characterise what the rules actually did — whether the preference was a legitimate ordering of State-quota seats, or whether it operated as a reservation in substance, carving out seats for one class of candidates while disadvantaging another.

Beneath that lay the larger question of principle. Article 14 guarantees equality before the law and the equal protection of the laws. The Supreme Court has, over decades, drawn firm limits around how far a State may favour its own residents in admissions to professional courses, and those limits have tightened at the postgraduate level. The petitioner's case put squarely before the High Court the question whether an institution-based preference — distinct in form from a residence or domicile requirement, but similar in effect — could survive Article 14, or whether it amounted to the same impermissible discrimination dressed in different language.

What the Court held

The Division Bench struck down Rule 11(a) and Rule 11(b). It held the rules to be ultra vires and violative of Article 14. The institution-based preference, the Court reasoned, amounted to a de-facto reservation carved out without authority: by funnelling State-quota postgraduate seats first to those who had obtained their MBBS from a Chhattisgarh college, the rules effectively reserved seats on a basis the Constitution does not permit. The State, the Court held, cannot discriminate between candidates for State-quota postgraduate seats on the ground of the institution from which the MBBS degree was obtained.

In reaching that conclusion the Court applied the Supreme Court's decision in Dr. Tanvi Behl v. Shrey Goel (2025 SCC OnLine SC 180). In Tanvi Behl, the Supreme Court held that residence- or domicile-based reservation in postgraduate medical courses is impermissible, reaffirming the long-standing principle of Pradeep Jain v. Union of India. The High Court read the institution-based filter in the Chhattisgarh rules as falling within the mischief that Tanvi Behl condemned: a preference that, whatever its form, sorts candidates for scarce postgraduate seats by reference to a connection — here, the place of undergraduate study — that Article 14 will not tolerate as a ground of distinction.

Analysis

The significance of Dr. Samriddhi Dubey lies in how it characterises the rule rather than in any novelty of doctrine. The constitutional principle it applies is settled. What the case does is refuse to let the principle be evaded by relabelling. A residence requirement and an institution requirement are not identical — one asks where a candidate lives, the other asks where she studied — but in the postgraduate-medical context they can produce the same constitutionally suspect result: seats effectively set aside for a favoured class, with outsiders relegated to whatever remains. By naming the Chhattisgarh rules a "de-facto reservation," the Court looked past their drafting to their operation, and held them to the same standard that governs an express reservation.

That move matters because admission rules are where high constitutional principle meets administrative ingenuity. A State that may not, after Tanvi Behl, reserve postgraduate seats by domicile has an obvious incentive to find a proxy — and "obtained your MBBS here" is a natural proxy, because the great majority of those who study undergraduate medicine in a State are its residents. The High Court's reasoning forecloses that route. The vice is not confined to the word "residence"; it lies in sorting candidates for professional-course seats on a ground extraneous to merit, and an institution filter does exactly that.

The judgment also illustrates the disciplining force of a clear Supreme Court ruling on State rule-making. Tanvi Behl was handed down earlier in 2025; within months, a State's freshly framed admission rules were tested against it and found wanting. The episode is a reminder that rules drafted to capture as many "home" candidates as possible must be measured against the equality guarantee as the Supreme Court has most recently expounded it, not against an older or more permissive understanding of how far localism may go.

There is a notable companion to the Chhattisgarh decision. One day earlier, on 19 November 2025, the Madhya Pradesh High Court — a Division Bench of Sanjeev Sachdeva, C.J., and Vinay Saraf, J. — quashed an analogous institutional-preference rule in Sawan Bohra v. State of Madhya Pradesh (2025 SCC OnLine MP 8456), there for breaching the limit on reservation, and likewise relying on Tanvi Behl and Pradeep Jain. That two High Courts arrived at the same conclusion within a day of each other, on the same principle, underscores how directly the recent Supreme Court line constrains State postgraduate-admission schemes across jurisdictions.

Why it matters

Dr. Samriddhi Dubey reinforces a proposition that runs from Pradeep Jain through Tanvi Behl and into the admission rules of the States: equality under Article 14 bars backdoor institution- or residence-based preference in admissions to professional courses, and the bar is at its strictest at the postgraduate level, where merit is meant to carry the greatest weight. A preference cannot be saved merely because it is framed in terms of where a candidate studied rather than where she lives; if its effect is to reserve seats for a favoured local class, it will be treated as the de-facto reservation it is.

For practitioners advising States, universities, or candidates, the lesson is concrete. Admission rules that prioritise State-quota postgraduate seats by reference to the institution or the State of undergraduate study now sit on weak ground, and the Tanvi Behl line is the authority against which they will be measured. For aspirants like the petitioner — natives of a State who studied elsewhere through all-India counselling — the decision restores access to home-State postgraduate seats that an institution filter had quietly placed beyond reach.

Sources

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