A) ABSTRACT / HEADNOTE

This case addresses the misapplication of horizontal and vertical reservations under the Madhya Pradesh Education Admission Rules, 2018. Meritorious candidates from reserved categories, entitled to Unreserved Government School (UR-GS) quota seats based on merit, were denied these seats due to a flawed implementation of reservation policies. The Supreme Court held the methodology adopted by the respondents as unsustainable and directed that the appellants be admitted to the UR-GS quota in the following academic session. The decision underscores the principle that horizontal and vertical reservations should not impede merit-based selection for open categories.

Keywords: NEET UG, Horizontal Reservation, Vertical Reservation, UR-GS Quota, Meritocracy.

B) CASE DETAILS

• i) Judgement Cause Title: Ramnaresh @ Rinku Kushwah and Others v. State of Madhya Pradesh and Others
• ii) Case Number: Civil Appeal No. 9628 of 2024
• iii) Judgement Date: 20 August 2024
• iv) Court: Supreme Court of India
• v) Quorum: B.R. Gavai, J., K.V. Viswanathan, J.
• vi) Author: Justice B.R. Gavai
• vii) Citation: [2024] 8 S.C.R. 916
• viii) Legal Provisions Involved: Madhya Pradesh Education Admission Rules, 2018; NEET UG Rules; Article 14 of the Constitution of India.
• ix) Judgments Overruled by the Case (if any): None mentioned.
• x) Case is Related to Which Law Subjects: Education Law, Constitutional Law, Administrative Law.

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appellants, candidates from reserved categories, qualified on merit for UR-GS quota seats in NEET UG 2023 under the Madhya Pradesh Education Admission Rules, 2018. However, these seats were wrongly allocated to the open category, ignoring their entitlement to UR-GS seats based on merit. The issue arose from an incorrect methodology applied in reconciling horizontal and vertical reservations. The High Court dismissed their writ petitions, prompting an appeal to the Supreme Court.

D) FACTS OF THE CASE

1. The Madhya Pradesh Education Admission Rules, 2018, included specific amendments defining quotas for Government School Students (GS).
2. The appellants appeared for NEET UG 2023 and were eligible for the UR-GS quota based on merit.
3. The State allocated UR-GS seats inconsistently, transferring 77 out of 89 UR-GS seats to the open category.
4. This transfer disregarded the appellants’ entitlement to UR-GS seats.
5. The appellants’ writ petitions challenging this allocation were dismissed by the Madhya Pradesh High Court.
6. The Supreme Court granted leave to appeal, reserved judgment, and directed that seats be kept vacant pending the outcome.

E) LEGAL ISSUES RAISED

1. Whether the respondents erred in misapplying horizontal and vertical reservations under the Madhya Pradesh Education Admission Rules, 2018?
2. Can meritorious reserved category candidates claim UR-GS seats based on their merit?
3. Should relief be granted for the next academic session when the admission process for the disputed session is complete?

F) PETITIONER / APPELLANT’S ARGUMENTS

1. The appellants’ counsel argued that the subdivision of GS quota into categories like UR-GS, SC-GS, and OBC-GS contravened principles established in Saurav Yadav v. State of Uttar Pradesh (2021).
2. The respondents’ methodology denied admission to more meritorious reserved candidates in favor of less qualified candidates under UR-GS.
3. The procedural flaw resulted in injustice, violating Article 14 of the Constitution and the principles of equal opportunity.
4. They sought immediate or deferred relief by way of admission in the next academic session.

G) RESPONDENT’S ARGUMENTS

1. The respondents’ counsel defended the allocation methodology as compliant with horizontal reservation principles.
2. They contended that horizontal reservations do not allow migration between vertical categories.
3. The High Court’s dismissal of the petitions was based on a lack of prima facie merit.

H) RELATED LEGAL PROVISIONS

• Madhya Pradesh Education Admission Rules, 2018 (as amended in 2019 and 2023).
• Article 14 of the Constitution of India.
• Precedents from the cases:
  • Indra Sawhney v. Union of India (1992).
  • Saurav Yadav v. State of Uttar Pradesh (2021).

I) JUDGEMENT

Ratio Decidendi

1. Horizontal reservations must allow meritorious candidates from reserved categories to compete for UR-GS seats.
2. Compartmentalizing categories contravenes merit-based principles.

Obiter Dicta

• The Court reiterated that “open category” includes all candidates based on merit, irrespective of reservation status.

Guidelines

1. Meritorious reserved category candidates must be considered for open seats in GS quota.
2. Allocation errors should not negate candidates’ legitimate claims.

J) CONCLUSION & COMMENTS

The judgment reinforces the primacy of merit in education policies while respecting reservation frameworks. It aligns with earlier rulings like Saurav Yadav and emphasizes procedural rectitude in reservations.

K) REFERENCES

1. Indra Sawhney v. Union of India (1992 Supp 3 SCC 217).
2. Saurav Yadav v. State of Uttar Pradesh (2021 4 SCC 542).
3. R.K. Sabharwal v. State of Punjab (1995 2 SCC 745).
4. Ritesh R. Sah v. Dr. Y.L. Yamul (1996 3 SCC 253).
5. Madhya Pradesh Education Admission Rules, 2018.