On 22 June 1984, a three-judge bench of Justice P.N. Bhagwati, Justice A.N. Sen and Justice Ranganath Misra held that wholesale state-domicile reservation in MBBS admissions is unconstitutional under Article 14 — every Indian citizen has only one domicile, the territory of India under Article 5. Institutional preference for graduates of the same institution was preserved as qualitatively distinct from domicile reservation; PG specialty admissions were directed to be on all-India merit. Saurabh Chaudri (2003) raised the all-India PG quota to 50% and Dr Tanvi Behl (2025) reaffirmed the framework against Chandigarh's UT-resident quota.