 "Unreserved seats open to meritorious SC/ST/OBC candidates: SC to High Court")
The Supreme Court set aside a Madhya Pradesh High Court order that had denied meritorious reserved category candidates admission under the unreserved (UR). The apex court, drawing upon the precedent set in the case of ‘Saurav Yadav and Others v State of Uttar Pradesh and Others’, asserted that candidates from reserved categories who qualify on their own merit must be admitted under the UR category, rather than being confined to their reserved category.
The bench, comprising Justice BR Gavai and Justice KV Viswanathan, on August 20, clarified that a meritorious candidate from the Scheduled Caste (SC), Scheduled Tribe (ST), or Other Backward Classes (OBC) categories who qualifies for a seat in the general category on merit should not be counted under the horizontal reservation for their respective reserved categories. Instead, they should be allotted seats under the general category, ensuring they are not deprived of opportunities available to them by merit.
Background of the case
The case arose from the admission process for MBBS seats in Madhya Pradesh, where 5 per cent of the total seats were reserved for students from government schools (GS). Due to unfilled vacancies in the GS-UR category, the seats were transferred to the open category as per Rule 2(g) of the Madhya Pradesh Education Admission Rules, 2018.
The appellants, who were meritorious students from reserved categories and had studied in government schools, argued that they should have been allocated the unreserved government school quota seats before those seats were released to the general open category. However, the High Court had dismissed their petitions, leading them to appeal to the Supreme Court.
Arguments made in the court
The appellants contended that the High Court had erred in its interpretation, failing to adhere to the principles established in the Saurav Yadav-case. They argued that less meritorious candidates had secured admission under the UR-GS seats, while they, despite being more qualified, were denied seats due to an incorrect application of horizontal and vertical reservation policies.
In contrast, the respondents defended the High Court’s decision, supporting a further sub-classification within the reserved GS categories (OBC-GS, ST-GS, SC-GS, UR-GS, and EWS-GS). They maintained that as this was a case of horizontal reservation, it was not feasible to transfer candidates from vertically reserved categories (SC/ ST/ OBC/ EWS) into the horizontal UR-GS category.
Supreme Court’s ruling
The Supreme Court found merit in the appellants’ arguments. Justice BR Gavai, in his judgment, highlighted that the appellants, despite scoring higher marks than the candidates in the unreserved GS category, were unjustly denied admission. The Court noted that this misapplication of the reservation methodology had led to a situation where less qualified candidates were admitted under the UR-GS seats, in violation of the principles established by the Supreme Court in previous rulings.
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The Court ruled that the refusal to allow meritorious reserved category candidates to claim unreserved seats was not legally sustainable. Consequently, the Court directed that the appellants should be admitted to the unreserved GS seats in the next academic session (2024-25).